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Contributors, by meeting the 33

requirements for public charity status

ordained ministers selected after

support test.

under section 509(a)(2) or

completing prescribed courses of study,

170(b)(1)(A)(vi). Instead, it meets the

literature of its own, established places of

The IRS does not update its records on

requirements for public charity status as a

worship, regular congregations, regular

an organization's public charity status

supporting organization under section

religious services, Sunday schools for the

based on a change the organization

509(a)(3). The organization should:

religious instruction of the young, and

makes on Schedule A (Form 990 or

schools for the preparation of its ministers.

1. Check the box for line 11 and either

990-EZ). Thus, an organization that

The IRS generally uses a combination of

line 11a, 11b, 11c, or 11d;

checks a public charity status different

these characteristics, together with other

from the reason stated in its exemption

2. Complete lines 11e and 11f;

facts and circumstances, to determine

letter or subsequent determination letter,

3. Complete the table on line 11g; and

whether an organization is considered a

although not required, may submit a

church for federal tax purposes.

4. Complete Part IV and (if applicable)

request to the IRS Exempt Organizations

Part V.

Line 2. Check the box for a school

Determinations Office for a determination

whose primary function is the presentation

letter confirming that it qualifies for the

Example 4. The organization received

of formal instruction, which regularly has a

new public charity status if the

an exemption letter that it is a supporting

faculty, a curriculum, an enrolled body of

organization wants the IRS records to

organization under section 509(a)(3).

students, and a place where educational

reflect that new public charity status (also

Based on Rev. Proc. 2014-10, 2014-2

activities are regularly conducted. A

referred to as “private foundation status”).

I.R.B. 293, the organization submitted a

private school must have a racially

See Form 8940, Request for

Form 8940 request to the IRS to change

nondiscriminatory policy toward its

Miscellaneous Determination, for

its classification to public charity status

students. For details about these

instructions. A $400 user fee must be

under section 509(a)(2). For the tax year,

requirements, see Schedule E (Form 990

submitted with such a request. See

it meets the requirements of section

or 990-EZ), Schools, and its related

Section 6.10 of Rev. Proc. 2014-8, 2014-1

509(a)(2). The organization received a

instructions.

I.R.B. 242.

determination letter that it has been

reclassified as a public charity under

An organization that checks the

A subordinate organization of a

section 509(a)(2). The organization should

box on line 2 must also complete

group exemption that is filing its own

TIP

check the box on line 9 and complete Part

Schedule E (Form 990 or

return, but has not received its own tax

III.

990-EZ), Schools.

exemption determination letter from the

Example 5. The organization received

IRS, should check the public charity status

Line 3. Check the box for an organization

an exemption letter that it is a public

box which most accurately describes its

whose main purpose is to provide hospital

charity under section 170(b)(1)(A)(vi). For

public charity status.

or medical care. A rehabilitation institution

the tax year, it does not meet the

An organization that does not know the

or an outpatient clinic can qualify as a

requirements for public charity status

public charity status stated in its

hospital if its principal purposes or

under section 170(b)(1)(A)(vi) or

exemption letter or subsequent

functions are the providing of hospital or

509(a)(2), or as a supporting organization

determination letter should call the

medical care, but the term does not

under section 509(a)(3). Nor does it meet

Exempt Organizations Customer Account

include medical schools, medical research

the requirements for public charity status

Services toll free at 1-877-829-5500 or

organizations, convalescent homes,

under any other provision of the Internal

write to:

homes for children or the aged, or

Revenue Code. The organization is a

vocational training institutions for

private foundation and should not file

Internal Revenue Service

handicapped individuals.

Form 990, Form 990-EZ, or Schedule A

TE/GE Customer Account Services

(Form 990 or 990-EZ) for the tax year but

Check the box on line 3 also for a

P.O. Box 2508

should file Form 990-PF instead.

cooperative hospital service organization

Cincinnati, OH 45201

described in section 501(e).

Example 6. The organization received

an exemption letter that it is a supporting

The definition of hospital for

See the following examples:

organization under section 509(a)(3). The

Schedule A (Form 990 or

TIP

Example 1. The organization received

letter does not state which type of

990-EZ), Part I, is different from

an exemption letter that it is a public

supporting organization it is. The

the definition for Schedule H (Form 990),

charity under section 170(b)(1)(A)(vi). For

organization should review the instructions

Hospitals. Accordingly, see Who Must File

the tax year, it meets the requirements for

for lines 11a–11d to determine which type

in the Instructions for Schedule H (Form

public charity status under section

best describes the organization. The

990) about whether the organization also

170(b)(1)(A)(vi). The organization should

organization may wish to file Form 8940 to

is required to complete Schedule H (Form

check the box on line 7 and complete

request a determination of type.

990).

Part II.

Line 1. Check the box for a church,

Example 2. The organization received

Line 4. Check the box for an organization

convention of churches, or association of

an exemption letter that it is a public

whose principal purpose or function is to

churches. Pub. 1828, Tax Guide for

charity under section 170(b)(1)(A)(vi). For

engage in medical research, and that is

Churches and Religious Organizations,

the tax year, it does not meet the

directly engaged in the continuous active

lists certain characteristics generally

requirements for public charity status

conduct of medical research in

attributed to churches. These attributes of

under section 170(b)(1)(A)(vi). Instead, it

conjunction with a hospital. The hospital

a church have been developed by the IRS

meets the requirements for public charity

must be described in section 501(c)(3) or

and by court decisions. They include:

status under section 509(a)(2). The

operated by the federal government, a

distinct legal existence, recognized creed

organization should check the box on

state or its political subdivision, a U.S.

and form of worship, definite and distinct

line 9 and complete Part III.

possession or its political subdivision, or

ecclesiastical government, formal code of

the District of Columbia.

doctrine and discipline, distinct religious

Example 3. The organization received

If the organization primarily gives funds

history, membership not associated with

an exemption letter that it is a public

any other church or denomination,

to other organizations (or grants and

charity under section 509(a)(2). For the

organization of ordained ministers,

scholarships to individuals) for them to do

tax year, it does not meet the

Instructions for Schedule A (Form 990 or 990-EZ)

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Instructions For Schedule A (Form 990 Or 990-Ez) - Public Charity Status And Public Support - 2014 Page 2

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