Prior guidance that certain requirements for tax-exempt status satisfied under state law obsoleted due to material change in law
Rev. Proc. 2024-22 and Rev. Rul. 2024-10
Requirements for tax-exempt status
The IRS today released two pieces of guidance obsoleting prior guidance that provided certain requirements for tax-exempt status were satisfied under state law, due to material changes in the relevant state law.
- Rev. Proc. 2024-22 obsoletes Rev. Proc. 82-2, which identified the circumstances in which an organization could satisfy Treas. Reg. § 1.501(c)(3)-1(b)(4) (requiring that the assets of a section 501(c)(3) organization be dedicated to an exempt purpose) by operation of the law of certain States or the District of Columbia, because due to material changes in the law of many jurisdictions since 1982, the jurisdictional list set forth in Rev. Proc. 82-2 is no longer accurate. Program Manager Technical Advice (PMTA) 2024-02 (dated April 23, 2024) was issued with updated guidance on state laws that satisfy the dissolution requirements of Treas. Reg. § 1.501(c)(3)-1(b)(4).
- Rev. Rul. 2024-10 obsoletes Rev. Rul. 75-38, which identified the District of Columbia and each State with statutory provisions that satisfied the private foundation governing instrument requirements of section 508(e), because due to material changes in the laws of a number of jurisdictions since 1975, the jurisdictional list set forth in Rev. Rul. 75-38 is no longer accurate. PMTA 2024-03 (dated April 23, 2024) was issued with updated guidance on state laws that satisfy the private foundation governing instrument requirements of section 508(e).
For more information, contact your usual KPMG tax professional or one of the following Washington National Tax professionals:
Ruth Madrigal | ruthmadrigal@kpmg.com
Preston Quesenberry | pquesenberry@kpmg.com
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