IRS Subordinate Organization Authorization
DUE SEPTEMBER 6, 2026!
 

EXCERPT FROM THE DESK OF THE COMMAND TEAM:

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During the EIN verification audit completed in June, National believed that the retroactive reinstatement of National’s federal tax-exempt status would also restore the subordinate Departments, Chapters, and Units previously covered under MOPH’s group exemption.

National’s exemption under Internal Revenue Code §501(c)(19) has been retroactively reinstated. However, on Monday, August 10, we received a courtesy call advising us that the IRS changed the process governing group exemptions the week prior to our audit submission. National’s reinstatement did not automatically restore the group exemption covering our subordinate organizations due to the rule change.

Under the revised IRS requirements, National must submit a new group-exemption application using Form 8940, Schedule Q. As part of that application, National must certify that each subordinate organization has provided written authorization to be included under National’s group exemption.

This requirement applies individually to every participating:

• Department

• Chapter

• Auxiliary Department

• Auxiliary Unit

• Other eligible subordinate organization

Each subordinate must have a valid EIN and must provide authorization signed by an officer who has personal knowledge of the information and authority to legally bind that subordinate organization.

National will collect these authorizations electronically through Dropbox Sign. A single authorization link will be distributed through the Regions and Departments. Each authorized representative will use that link to:

1. Identify the subordinate organization.

2. Enter its exact legal name, EIN, Department, and Chapter or Unit number.

3. Enter the representative’s name, title, email address, and telephone number.

4. Authorize National to include the subordinate in the group-exemption application.

5. Acknowledge National’s authority to remove the subordinate from the group exemption, with or without cause, as permitted by IRS Revenue Procedure 2026-8.

6. Certify that the signer has personal knowledge of the information and authority to legally bind the subordinate.

7. Sign and submit the authorization electronically.

 

Deadline and filing schedule

All authorizations intended for the first group-exemption application must be completed no later than September 6, 2026.

National intends to submit the Form 8940 group-exemption application on September 8, 2026.

A subordinate organization that does not provide a complete and verifiable signed authorization by September 6 cannot be included in the initial submission. After the first application has been processed, National will coordinate a later submission for eligible subordinate organizations that missed the deadline. This could substantially delay recognition of those organizations under National’s group exemption.

Required tracking process

• After signing, the representative should receive an email containing the completed authorization PDF.

• The representative must retain a copy in the subordinate organization’s permanent records.

• Chapter and Unit representatives must forward the completed authorization to their Department Commander or Department Adjutant.

• Departments will track completion by their Chapters and Units.

• Once every active subordinate within a Department has either completed the authorization or been identified as outstanding, the Department will report its status to the Region Command Team.

• Region Commanders will track Department reports and provide National with the status of their Regions.

• National will compile those reports with the signed authorizations received through Dropbox Sign for submittal to the IRS.

Important completion requirements

Representatives must use:

• The subordinate’s exact legal name associated with its EIN.

• The subordinate’s own EIN—not National’s EIN or another organization’s EIN.

• The correct Department, Chapter, or Unit number.

• The name and official title of the officer signing.

• An email address the signer can access, because Dropbox Sign will send the completed authorization to that address.

The authorization is not an application by the subordinate organization. It authorizes National to include that subordinate in National’s group-exemption application.

This is a one-time authorization for the present group application. Once the group exemption is approved, National’s continuing administration will generally consist of annual subordinate verification and reporting similar to the EIN audit completed in June. Newly formed or later-added subordinate organizations will still need to satisfy the applicable authorization and reporting requirements before being added.

Immediate leadership action requested

Region Commanders and Department Commanders must distribute this notice and the Dropbox Sign link promptly. Please begin tracking responses immediately and follow up directly with any Chapter or Unit that has not completed its authorization.

The September 6th deadline is firm. Your timely assistance is essential to restoring eligible subordinate organizations under National’s 501(c)(19) group tax-exemption umbrella.

IMPORTANT: DO NOT CONTACT THE IRS DIRECTLY

All questions concerning this group-exemption process must be forwarded through your established leadership channel:

Chapter or Unit → Department (if applicable) → Region → National

National is serving as the single point of contact with the IRS for this matter. This is already a complex process involving National’s reinstatement, the former group exemption, hundreds of subordinate organizations, and the new IRS requirements.

Separate contacts with the IRS by individual Departments, Chapters, Units, officers, or members could create conflicting information, duplicate correspondence, and additional records that the IRS must review and reconcile. That could compound the issues and delay National’s application for everyone.

Please direct all questions to your Department or Region leadership. Questions requiring IRS clarification will be consolidated and addressed by National through the appropriate channel.

  

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REGION 1, 3, and 6  FRAN HOLTGREVEN --- Fran.MOPHA@Gmail.com

REGION 2 BAILEY PAUGH --- BaileyPaugh1011@gmail.com

Region 4 (TEMP) LINDA BELLIS ---- LindaB.MOPHA@gmail.com

Region 5 DORIS WILLIAMS --- Region5MOPHAUX@gmail.com