IRS TE/GE issues new technical guides for title-holding corporations
Update and combine Audit Technique Guides (ATG) with other technical content
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March 3, 2025
The IRS Tax Exempt and Government Entities (TE/GE) division today published two new technical guides (TGs) that update and combine the Audit Technique Guides (ATG) with other technical content. These guides are comprehensive, issue-specific documents that replace the corresponding ATGs once completed.
According to an IRS transmittal message (March 3, 2025):
- TG 2 addresses exemption qualifications for single-parent title-holding corporations under section 501(c)(2). These corporations provide a means for exempt organizations to transfer property titles to address legal considerations such as limiting liability exposure, enhancing borrowing ability, or complying with state law requirements. To qualify, a corporation must be organized exclusively for holding title to property, collecting income from it, and transferring the entire amount, minus expenses, to an organization exempt under section 501(a).
- TG 25 covers exemption qualifications for multiple-parent title-holding organizations under section 501(c)(25). These organizations, often used as investment vehicles, allow unrelated tax-exempt entities, such as pension trusts, to pool investments and invest in real property. Generally, tax-exempt title-holding organizations provide a practical means for exempt organizations to transfer title to property in order to address legal considerations outside of exemption, such as limiting liability exposure, enhancing borrowing ability, or complying with state law requirements.
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