Tax Exempt Letter of Certification
Below is the text version of the tax exempt letter of certification, which is available as a PDF.
Internal Revenue Service
Department of the Treasury
District Director, Baltimore District
31 Hopkins Plaza, Baltimore Md. 21201
July 20, 1994
Ms. Deidre Halloran
Associate General Counsel
United States Catholic Conference
3211 4th Street N.E.
Washington, D.C. 20017-1194
Dear Ms. Halloran:
In a ruling dated March 25, 1946, we held that the agencies and instrumentalities and all educational, charitable and religious institutions operated, supervised, or controlled by or in connection with the Roman Catholic Church in the United States, its territories or possessions appearing in the Official Catholic Directory for 1946, are entitled to exemption from federal income tax under the provisions of section 101(6) of the Internal Revenue Code of 1939, which corresponds to section (501)(c)(3) of the 1986 Code. This ruling has been updated annually to cover the activities added to or deleted from the Directory.
The Official Catholic Directory for 1994 shows the names or addresses of all agencies and instrumentalities and all educational, charitable, and religious institutions operated by the Roman Catholic Church in the United States, its territories and possessions in existence at the time the Directory was published. It is understood that each of these is a non-profit organization, that no part of the net earnings thereof inures to the benefit of any individual, that no substantial part of their activities is for promotion of legislation, and that none are private foundations under section 509(a) of the Code.
Based on all information submitted, we conclude that the agencies and instrumentalities and educational, charitable, and religious institutions operated, supervised or controlled by or in connection with the Roman Catholic Church in the United States, its territories or possessions appearing in the Official Catholic Directory for 1994 are exempt from federal tax under section 501(c)(3) of the Code.
Donors may deduct contributions to the agencies, instrumentalities and institutions referred to above, as provided by section 170 of the Code. Bequests, legacies, devises, transfers, or gifts to them or for their use are deductible for federal estate and gift tax purposes under sections 2055, 2106, and 2522 of the Code.
Beginning January, 1984, unless specifically excepted, you and your subordinates must pay tax under the Federal Insurance Contributions Act (Social Security taxes) for each employee who is paid $100 or more in a calendar year. You and your subordinates are not liable for tax under the Federal Unemployment Act (FUTA).
Next year, within 90 days before the close of your annual accounting period, or by May 31, the date established by our letter of April 28, 1975, which gave an extension of time to file the information, please send one copy of the Official Catholic Directory of 1994 for each Internal Revenue District in which one or more of your subordinates are located, with four additional copies to this office.
The conditions concerning the retention of your group exemption as set forth in our previous determination letter of August 17, 1983, remain in full force and effect.
Paul W. Harrington