Church-affiliated school exempted from Form 990 filing

Plain-English summary

An educational organization operating below the college level asked to be excused from filing Form 990. Based on the submitted information, the IRS classified it as a school with a general academic program that is affiliated with a church or operated by a religious order. That classification falls within the regulatory exception from Form 990 filing, so the IRS said it would update its records accordingly. The private school must still file Form 5578 annually to certify racial nondiscrimination under Revenue Procedure 75-50 and must continue meeting its other § 501(c)(3) responsibilities.

Ruling snapshot

• Question: Is a below-college-level educational organization affiliated with a church exempt from filing Form 990?
• Outcome: Approved; Form 990 is not required, but annual Form 5578 racial-nondiscrimination certification remains required
• Key authorities: Treas. Reg. § 1.6033-2(g)(1)(vii), (h)(2); IRC §§ 170(b)(1)(A)(ii) and 501(c)(3); Rev. Proc. 75-50

Full text (IRS public release)

Department of the Treasury Date:
Internal Revenue Service 04/02/2025
Tax Exempt and Government Entities Employer ID number:
PO Box 2508
Cincinnati, OH 45201 Person to contact:
Name:
ID number:
Telephone:
Form 990 required:
No
Release Number: 202526015
Release Date: 6/27/2025
UIL:
6033.01-00

Dear

Why you're receiving this letter
This is in response to your July 25, 2024 request to be exempt from the requirement to file
Form 990, Return of Organization Exempt from Income Tax.

Treasury Regulation Section 1.6033-2(g)(1)(vii) provides that an educational organization (below college level)
described in Internal Revenue Code (IRC) Section 170(b)(1)(A)(ii) with a program of general academic nature
and is affiliated with a church, or operated by a religious order, isn't required to file Form 990. Treas. Reg. Section
1.6033-2(h)(2) clarifies what it means to be affiliated with a church. Based on the information you provided,
we determined you qualify for classification as one of these educational organizations. Therefore, in accordance
with Treas. Reg. Section 1.6033-2(g)(1)(vii), you're not required to file Form 990. We'll update our records

accordingly.

However, be aware that Section 4.06 of Revenue Procedure 75-50 requires private schools provide us with
annual certification of racial nondiscrimination. This is normally done on Form 990 (Schedule E), Schools.

If you don't file Form 990, you must complete Form 5578, Annual Certificate of Racial Nondiscrimination for a
Private School Exempt from Federal Income Tax, annually to certify you're complying with Rev. Proc. 75-50.

What you need to know

As an organization exempt from federal income tax under IRC Section 501(c)(3), you must fulfill other
requirements. You can find helpful information about your responsibilities as tax exempt organization in
Publication 4221-PC, Compliance Guide for 501(c)(3) Public Charities.

Additional information
We'll make this determination letter available for public inspection after making deletions as
required by IRC Section 6110, such as the names, addresses, and other identifying details...
We've enclosed Letter 437, Notice of Intention to Disclose Rulings, and a copy of the letter
that shows our proposed deletions.

• If you disagree with our proposed deletions, follow the instructions in the Letter 437 on

how to notify us.
• If you agree with our deletions, you don't need to take any further action.

If you have questions, you can call the contact person shown at the top of this letter. Keep a
copy of this letter for your records.

We sent a copy of this letter to the representative as indicated on your power of attorney.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:
Letter 437
Redacted Letter 4715