Tax alert

2026 annual revenue procedures for exempt organizations

EO-specific user fees remain unchanged

January 14, 2026
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Federal tax Nonprofit

Annual revenue procedures provide minimal changes for exempt organizations

The 2026 annual revenue procedures, effective Dec. 29, 2025, outline the fees and processes applicable to exempt organizations. While the applicable user fees generally remain unchanged from 2025, Rev. Proc. 2026-5 contains modest revisions and clarifications. 


Summary of exempt organization revenue procedures

The annual revenue procedures that affect exempt organizations are as follows:

  • Rev. Proc. 2026-1 – Letter rulings, information letters, and determination letters
  • Rev. Proc. 2026-2 – Technical advice
  • Rev. Proc. 2026-3 – Areas in which rulings will not be issued (domestic)
  • Rev. Proc. 2026-5 – Determination letters (exempt organizations)

User fees remain unchanged

Exempt organization-specific user fees, set forth in Rev. Proc. 2026-5, remain the same as in 2025:

  • $3,500: Requests for advance approval (set-asides, grantmaking procedures, and voter registration activities).
  • $3,500: Group exemption letters (not currently being accepted).
  • $600: Most other requests made on Form 8940, Request for Miscellaneous Determination.

User fees governing private letter rulings (PLRs), set forth in Rev. Proc. 2026-1, also remain the same:

  • Private letter ruling requests: $43,700
  • Reduced fees for certain small organizations: $3,450 and $9,775.
  • Most requests for 9100 relief (i.e., extensions of time to make certain elections): $14,500.
  • Substantially identical requests: $4,370.

Donors of highly valued artwork may obtain a statement of value from the IRS for $8,400 for up to three items.
Additional items are $800 each. More information about statements of value is available in Rev. Proc. 96-15.

Read more in last year’s summary.

Other updates

While the annual revenue procedures generally did not have any substantive updates affecting exempt organizations, Rev. Proc. 2026-5 includes several minor updates:

  • Declaratory judgment period clarification: Time spent responding to IRS requests for additional information does not count toward the 270-day period regardless of exemption application or organization type. This clarification aligns the revenue procedure with amendments made to section 7428 in 2015.

  • Modernized submission procedures: Formally encourages taxpayers to use fax and the IRS Document Upload Tool for submitting supplemental information.

  • Private foundation intent to terminate: Clarifies that Form 8940 is the exclusive mechanism for private foundations to notify the IRS of their intent to terminate by subjecting such notices to the revenue procedure.

  • Exceptions from Appeals: By specifically referencing Reg. section 301.7803-2(c), creates alignment among the revenue procedure, the Taxpayer First Act, and the 2025 regulations that identify issues and matters excluded from consideration by the Independent Office of Appeals. For example, Appeals cannot review adverse determinations or revocations of exempt status that were based on technical advice memoranda (TAMs). 

RSM contributors

  • Alexandra O. Mitchell
    Education Sector Leader, Principal
  • Brianna Mooty
    Senior Manager
  • Michelle McCarthy
    Senior Manager
  • Lauren Nowakowski
    Senior Manager

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