IRS TEGE Division to Focus on Hospitals, NIL Collectives, and Fraud

The IRS Tax-Exempt & Governmental Entities (TEGE) Division recently released its Fiscal Year 2026 Program Letter. Besides the long list of promised process and customer service improvements, and necessary steps to implement provisions of the One Big Beautiful Bill Act, the letter provides a short list of enforcement priorities, focusing primarily on “tax-exempt hospitals, tax-exempt collectives utilizing Name, Image, and Likeness (NIL), and combatting fraud/abusive transactions.” To what extent those priorities are reflected in actual enforcement actions remains to be seen, especially given the reduced funding of the IRS for the current fiscal year and uncertainty about the status of current IRS leadership, as highlighted by a March 9th letter from three prominent Senate Democrats.