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 for that notice is about December 23, 2026. Earlier is safer: we suggest every notice arrives by December 9.
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
| Notice arrives | 30 days end | Margin left |
|---|---|---|
| Sunday, November 1, 2026 | Tuesday, December 1, 2026 | 7 weeks |
| Monday, November 16, 2026 | Wednesday, December 16, 2026 | 5 weeks |
| Tuesday, December 1, 2026 | Thursday, December 31, 2026 | 3 weeks |
| Wednesday, December 9, 2026 | Friday, January 8, 2027 | 2 weeks |
| Tuesday, December 15, 2026 | Thursday, January 14, 2027 | 8 days |
| Wednesday, December 23, 2026 | Friday, January 22, 2027 | None |
A notice that arrives December 23 runs out on the last day of the transition period itself. Any later and the removal cannot be filed in time. The IRS has not said how it counts the 30 days, whether a fax's sending date is its submission date, or whether a fax on January 22 counts as "before" the end, so plan with margin.
Why we suggest early December at the latest
- Delivery. The rule does not say how notice is given or when it counts. If you mail it, delivery takes days. Use a method that proves the arrival date, 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. We aim for the last fax by January 15.
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 arrive 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, and a licensed reviewer checks the reasons and dates; we do not make that call.
Have chapters to remove?
We draft the notice letters first, so they can go out in November. Start with a free readiness sheet.
Sources
- Rev. Proc. 2026-8, 2026-4 I.R.B. 380 (PDF): sections 3.11, 7.01, 8.02, 9.03, 9.05, 9.06 and 12.02(2)
- IRS EO Update, July 14, 2026: Form 15644 by fax at 833-312-5228; updates at any time
Dates computed by adding 30 calendar days. Checked October 13 and 14, 2026. General information, not legal advice.