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What Nonprofits Need to Know Before Restructuring Their Legal Form

ARTICLE | October 29, 2026

Authored by Vasquez + Company

Restructuring can be a smart move for 501(c) organizations looking to reduce costs, combine resources, or shift to a new state. But before making any changes, nonprofit leaders need to understand the IRS rules governing whether their organization can retain its tax-exempt status through the process. Under IRS Revenue Procedure 2018-15, qualifying organizations may avoid filing a new exemption application, but only if they meet specific conditions. Knowing where the relief applies, and where it does not, is critical to protecting your organization's exempt status, EIN, and exempt purposes.

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Our firm provides the information for general guidance only, and does not constitute the provision of legal advice, tax advice, accounting services, investment advice, or professional consulting of any kind. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal, or other competent advisers. Before making any decision or taking any action, you should consult a professional adviser who has been provided with all pertinent facts relevant to your particular situation. This article is not intended to be used, and cannot be used by any taxpayer, for the purpose of avoiding accuracy-related penalties that may be imposed on the taxpayer. The information is provided “as is,” with no assurance or guarantee of completeness, accuracy, or timeliness of the information, and without warranty of any kind, express or implied, including but not limited to warranties of performance, merchantability, and fitness for a particular purpose. 

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