Insights

December 23 is the real cutoff for removing a chapter

October 13, 2026 · 4 minute read

The transition period ends January 22, 2027, but a chapter cannot be removed until it has had at least 30 days' notice. Counted back, the last day to send that notice is about December 23, 2026. Earlier is safer.

What the rule says

Three sentences in Rev. Proc. 2026-8 set the timing:

"A central organization must provide a subordinate organization with at least 30 days' notice prior to removing the subordinate organization from the central organization's group exemption letter." (s. 8.02(3))

"The central organization may not submit the SGRI removing the subordinate organization prior to the end of the 30-day period set forth in section 8.02(3) of this revenue procedure." (s. 8.02(2))

The transition actions "are accomplished through SGRI submissions and must be completed before the transition period ends on January 22, 2027." (s. 12.02(2)(f))

A chapter leaves the letter on the date you notify the IRS on Form 15644 (s. 8.02(2)). That fax cannot go before the 30 days are up, and it has to go before the transition period ends.

Counting back

A notice sent December 23 runs out on the last day of the transition period itself. Any later and the removal cannot be filed in time.

Why we suggest November

• The rule does not say how notice is given or when it counts. If you mail it, delivery takes days. Leave margin, and ask your own counsel how notice should be given under your bylaws or chapter agreements.
• The holidays. Chapter officers, your own officers and your signer are often away between December 24 and January 1.
• A chapter may answer. It may send records showing it is in your paragraph after all, or that it is under your supervision. Time to look at that is time well spent.
• The fax has to go through. Form 15644 is fax only. Keep the confirmation page, and leave a few days in case a fax fails.

If your fiscal year ends December 31

Your annual Form 15644 window runs from October 2 to December 1, 2026: 90 to 30 days before your year end (s. 7.01). To put removals in that same annual filing, notices would have to go out by about November 1. If they go later, send the removal as a separate update. The revenue procedure lets you send updates at any time.

After the fax

Once the removal is filed, you must tell the chapter it has been removed and how it can get recognition of its exemption on its own, or claim exemption without recognition where that is allowed (s. 8.02(3), 9.05 and 9.06). Until it does, the IRS does not recognize its exemption (s. 9.03). Keep a copy of both notices with the fax confirmation in your group exemption file.

Who decides which chapters to remove

Your organization does. The rule says which chapters cannot stay: those outside your group's 501(c) paragraph, and those you cannot show are affiliated and under your general supervision or control (s. 12.02(2)(d) and (e)). Whether a particular chapter passes that test is a judgment for your officers, with your counsel if the case is hard. We prepare the notices and the filing; we do not make that call.