IRS TE/GE division provides new technical guides addressing section 509(a)(3) organizations

The IRS Tax Exempt and Government Entities (TE/GE) division published three new technical guides (TGs) addressing supporting organizations described in section 509(a)(3). Supporting organizations that qualify as public charities under section 509(a)(3) are organized and operated exclusively to support one or more section 509(a)(1) or (2) organizations. 

Section 509(a)(3) supporting organizations are further categorized as Type I, II or III, based on the type of relationship they have with their supported organization(s). The new TGs feature illustrations that diagram each type and assist in assessing the factors that apply in specific situations. 

The three TGs released today are:

• TG 3-31: Foundation Classification – Type I Supporting Organizations – IRC Section 509(a)(3), Publication 6015
• TG 3-32: Foundation Classification – Type II Supporting Organizations – IRC Section 509(a)(3), Publication 6016
• TG 3-33: Foundation Classification – Type III Supporting Organizations – IRC Section 509(a)(3), Publication 6017

According to an IRS transmittal message (September 12, 2024), TGs are comprehensive, issue-specific documents that update and combine the existing IRS.gov Audit Technique Guides (ATGs) with other technical content, replacing the corresponding ATGs.

Read all ATGS and TGs for exempt organizations on the IRS website.
 

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