Correction to 2025 Form 8940 Instructions
Summary
The IRS issued a correction to the 2025 Instructions for Form 8940, specifically regarding Schedule Q, Line 7. Lines 7a through 7d were incorrectly added and have been removed, with the information consolidated into a single Line 7. This correction clarifies the requirements for demonstrating a subordinate organization's affiliation with a central organization.
What changed
The Internal Revenue Service has issued a correction to the 2025 Instructions for Form 8940, impacting page 24 concerning Schedule Q, Line 7. The incorrect inclusion of lines 7a, 7b, 7c, and 7d has been rectified; these lines have been removed and the relevant information consolidated into a single Line 7. This change clarifies the criteria for establishing affiliation between a subordinate organization and its central organization, including examples related to group exemption numbers, directories, and shared religious bonds.
Compliance officers for tax-exempt organizations should ensure they are using the corrected instructions for Form 8940. While this is a minor correction to form instructions and does not impose new obligations or penalties, it is crucial for accurate filing. The updated guidance provides specific examples of facts and circumstances that demonstrate affiliation and control, which may be relevant for organizations seeking or maintaining tax-exempt status under section 501(c).
What to do next
- Ensure use of corrected 2025 Instructions for Form 8940, page 24.
Source document (simplified)
If you downloaded or printed the 2025 Instructions for Form 8940 prior to Feb. 13, 2026, please note the following correction to page 24.
Under Schedule Q, Line 7 we have removed lines 7a, 7b, 7c, and 7d. The lines were added incorrectly. The information has been restated into one line 7 only. The corrected instructions are below.
Line 7. A subordinate organization’s affiliation with the central organization is demonstrated by facts and circumstances showing that is a chapter, local, post, or unit of the central organization. Examples of affiliation include:
- Inclusion of the subordinate organization’s information on a group return described in section 1.6033-2(d) that includes the four-digit group exemption number;
- The current inclusion of the subordinate organization in a directory of subordinate organizations updated annually by the central organization; or
In the case of a subordinate organization that is a church or a convention or association of churches, the sharing of common religious bonds or convictions with the central organization.
A subordinate organization is subject to the central organization’s general supervision if the central organization:Annually obtains, reviews, and retains information on the subordinate organization’s finances, activities, and compliance with annual filing requirements; and
Annually transmits (including electronically) written information to (or otherwise educates) the subordinate organization about the requirements to maintain tax-exempt status under the appropriate paragraph of section 501(c), including annual filing requirements, if applicable.
A subordinate organization is subject to the central organization’s control if:The central organization appoints the subordinate organization’s directors or trustees who possess a majority of the voting power with respect to the subordinate organization’s governance,
The central organization appoints a majority of the subordinate organization’s officers,
The subordinate organization’s directors or trustees possessing a majority of the voting power with respect to the subordinate organization’s governance are directors or trustees of the central organization,
A majority of the subordinate organization’s officers are officers of the central organization, or
The central organization and the subordinate organization enter into a written agreement that evidences the central organization’s control over the subordinate organization’s activities and operations.
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