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IRS letter ruling confirms a church's integrated auxiliary need not file Form 990

The letter, dated July 16 and made public Oct. 9 with the organization's name removed, applies the Treasury definition of an integrated auxiliary of a church. It binds only the organization that asked and cannot be cited as precedent.

A wide parking lot under an overcast sky, with white tents, shopping carts and a box truck beside a long two-story building and tall evergreen trees; one person walks in the distance
Food pantry tents beside a church building in Tukwila, Wash., in October 2011.U.S. Department of Agriculture

Washington. The Internal Revenue Service has told a 501(c)(3) organization that it qualifies as an integrated auxiliary of a church and so does not have to file Form 990, the annual information return most tax-exempt organizations file. The letter, dated July 16, was made public on Oct. 9 as written determination 202641018, with the organization's name and other identifying details removed.

It does not say what the organization does, which church it is tied to or what facts it gave. It says only that, based on the information provided, the organization qualifies, and that it must still meet the other requirements for 501(c)(3) organizations. It is signed by Stephen A. Martin, director of Exempt Organizations Rulings and Agreements.

What counts as an integrated auxiliary

The Internal Revenue Code lists churches, their integrated auxiliaries and conventions or associations of churches among the mandatory exceptions to the annual return, apart from those the IRS may grant at its discretion. Treasury regulations define an integrated auxiliary as a 501(c)(3) public charity or supporting organization that is affiliated with a church or a convention or association of churches and is internally supported.

Affiliation can come from a church's group exemption letter, from control by or in connection with a church, or from other facts, such as bylaws affirming shared doctrine, a church's power to appoint a director, or a rule that assets go to the church on dissolution. An organization fails the internal support test only if it both sells goods, services or admissions to the general public more than incidentally and normally receives more than half its support from government, public fundraising and such sales. The regulation's examples count a church's weekly newspaper as an integrated auxiliary, but not a retirement home or a hospital that serves the general public and gets most of its support from fees. Affiliated men's and women's organizations, seminaries, mission societies and youth groups qualify whatever their support.

Who can rely on it

Only the organization that asked. Under Section 6110 of the tax code, a written determination may not be used or cited as precedent, and the IRS says other taxpayers may not rely on a private letter ruling as precedent. For other church-affiliated charities, it shows only how the IRS applied the definition to facts it does not disclose.

In The National Law Review on Oct. 23, Felix C. Pelzer and Hannah Clarke Campbell of the law firm Shumaker said the ruling is consistent with other nearly identical determinations this year, which they said suggests the IRS is handling such requests routinely. Because the relief rests on the mandatory exception, they wrote, church-affiliated organizations that meet the definition may want to consider asking for the same determination.

About this story

501c3.help wrote this story from the sources listed with it, not from material an organization sent. Our editors approved it on Oct. 26, 2026. Stories in The Nonprofit Herald are free, and nothing is asked in return. Editorial rules.

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