Exempt organizations - Uncle Fed's Tax*Board
Exempt organizations - Uncle Fed's Tax*Board
Exempt organizations - Uncle Fed's Tax*Board
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nization whose membership is limited to the<br />
employees of an employer in a particular municipality<br />
and whose primary purpose is to obtain for<br />
its members discount prices on merchandise, services,<br />
and activities is not exempt as a local<br />
association of employees under section 501(c)(4).<br />
§1.501(c)(4)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 79-128, 1979-1 C.B. 197.<br />
218.359 Employees’ association; membership.<br />
For purposes of section 501(c)(4) the term<br />
“employees” includes retired employees who<br />
were members of an employees’ association at the<br />
time of retirement. §1.501(c)(4)–1. (Sec. 501, ’86<br />
Code.)<br />
Rev. Rul. 74-281, 1974-1 C.B. 133.<br />
218.360 Employees’ association; operating<br />
bus for members. An organization whose primary<br />
purpose is the operation of a bus for the convenience<br />
of its members, using the income from<br />
fares to pay expenses, is not exempt as a local<br />
association of employees. §§39.101(8)-1,<br />
1.501(c)(4)-1. (Sec. 101(8), ’39 Code; Sec. 501,<br />
’86 Code.)<br />
Rev. Rul. 55-311, 1955-1 C.B. 72.<br />
218.361 Employees’ association; operating<br />
gasoline station. An employees’ association<br />
organized exclusively for recreational purposes<br />
operates a gasoline station on property owned by<br />
the employer of its members. Sales are limited to<br />
its members and to the employer company, and<br />
income is used exclusively for members’ recreation.<br />
Neither the operation of the gasoline station,<br />
nor the selling of gasoline and oil to the employer<br />
company adversely affects the association’s qualification<br />
for exemption since all of its income is<br />
used for recreational purposes, and the income<br />
from sales to the employer is considered a form of<br />
employer support of the association.<br />
§1.501(c)(4)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 66-180, 1966-1 C.B. 144.<br />
218.362 Employees’ association; retirement<br />
or death benefits. An organization of employees<br />
whose purpose is to pay lump sum retirement<br />
benefits to its eligible members or death benefits<br />
to their survivors does not qualify for exemption.<br />
§1.501(c)(4)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 66-59, 1966-1 C.B. 142.<br />
218.363 Employees’ beneficiary association;<br />
obsolete procedures. Rev. Proc. 66-30 is<br />
declared obsolete with respect to future transactions<br />
of section 501(c)(9) <strong>organizations</strong>.<br />
§§1.501(c)(9)-1, 301.7805-1. (Sec. 601.201,<br />
S.P.R.; Secs. 501, 7805, ’86 Code.)<br />
Rev. Proc. 82-46, 1982-2 C.B. 788.<br />
218.364 Employees’ beneficiary association;<br />
obsolete rulings. Certain rulings are declared<br />
obsolete with respect to future transactions of section<br />
501(c)(9) <strong>organizations</strong>. Rev. Ruls. 57–61,<br />
57-494, 58-442, 59-28, 64–258, and 65–81 obsolete.<br />
§§1.501(c)(9)-1, 301.7805-1. (Secs. 501,<br />
7805; ’86 Code.)<br />
Rev. Rul. 82-148, 1982-2 C.B. 401.<br />
218.365 Employees’ beneficiary association;<br />
reimbursed medicare premium. A section<br />
501(c)(9) organization does not jeopardize its<br />
exemption by reimbursing its members for premiums<br />
paid under the medical benefits program<br />
(medicare) provided under the Social Security<br />
Amendments of 1965. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 66-212, 1966-2 C.B. 230.<br />
218.366 Employees’ beneficiary association;<br />
workmen’s compensation benefits. An association<br />
formed by a corporation to provide workmen’s<br />
compensation benefits that the corporation<br />
was already obligated to pay under State law does<br />
not qualify for exemption. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 74-18, 1974-1 C.B. 139.<br />
218.367 Employees’ pensions; discretionary<br />
distribution. An exempt organization’s payment<br />
of reasonable pensions to retired employees at the<br />
discretion of its board of directors does not<br />
adversely affect its exempt status. §1.501(c)(3)–1.<br />
(Sec. 501, ’86 Code.)<br />
Rev. Rul. 73-126, 1973-1 C.B. 220.<br />
218.368 Employees’ trust. A trust organized<br />
primarily to pay pensions to retired employees,<br />
and to provide incidental benefits to employees or<br />
their beneficiaries in times of need, is not exempt<br />
as a charitable organization. Contributions to such<br />
a trust are not deductible by the donors as charitable<br />
contributions. (Secs. 170, 501; ’86 Code.)<br />
Rev. Rul. 56-138, 1956-1 C.B. 202.<br />
218.369 Employment assistance to the<br />
elderly. A corporation organized to rehabilitate<br />
unemployed persons over a stated age by educating<br />
the general public in the special qualifications<br />
of such persons, combating prejudice against<br />
employment of such persons, and securing<br />
employment of its members, is not exempt from<br />
tax as a charitable organization where the members<br />
were the beneficiaries and expected to contribute<br />
to the organization in return for the benefits<br />
secured. However, the corporation may qualify for<br />
exemption as a civic organization. Distinguished<br />
by Rev. Rul. 66-257. §1.501(c)(4)-1. (Sec. 501,<br />
’86 Code.)<br />
Rev. Rul. 57-297, 1957-2 C.B. 307.<br />
218.370 Employment assistance to the<br />
elderly. A nonprofit organization which aids<br />
elderly unemployed persons of limited means in<br />
obtaining employment by providing them with<br />
free services and by educating the public in the<br />
employment capabilities of elderly persons qualifies<br />
for exemption. Rev. Rul. 57–297 distinguished.<br />
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 66-257, 1966-2 C.B. 212.<br />
218.371 Engineering society; heating and air<br />
conditioning. An engineering society formed to<br />
advance the arts and sciences of heating, ventilating,<br />
and air conditioning for the benefit of the general<br />
public by providing facilities for research and<br />
the dissemination of scientific knowledge qualifies<br />
for exemption. §§1.501(c)(3)-1,<br />
1.501(c)(6)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 71-506, 1971-2 C.B. 233.<br />
218.372 Environmental conservancy. A nonprofit<br />
organization formed for the purpose of preserving<br />
the natural environment by acquiring, by<br />
gift or purchase, ecologically significant undeveloped<br />
land, and either maintaining the land itself<br />
with limited public access or transferring the land<br />
to a government conservation agency by outright<br />
gift or being reimbursed by the agency for its cost,<br />
qualifies for exemption. Distinguished by Rev.<br />
Rul. 78-384. §1.501(c)(3)-1. (Sec. 501, ’86<br />
Code.)<br />
Rev. Rul. 76-204, 1976-1 C.B. 152.<br />
218.373 Environmental conservancy. A nonprofit<br />
organization that owns farmland and<br />
restricts its use to farming or other uses the organization<br />
deems ecologically suitable, but is not<br />
operated for the purpose of preserving ecologically<br />
significant land and does not otherwise<br />
establish that it serves a charitable purpose, does<br />
not qualify for exemption under section 501(c)(3).<br />
Rev. Rul. 76-204 distinguished. §1.501(c)(3)-1.<br />
(Sec. 501, ’86 Code.)<br />
Rev. Rul. 78-384, 1978-2 C.B. 174.<br />
218.374 Environmental disputes; international<br />
mediation. An otherwise qualifying organization<br />
that engages in legal research concerning<br />
various means of adjusting and resolving international<br />
environmental disputes and arranges for,<br />
and participates in, the resolution of such disputes<br />
<strong>Exempt</strong> <strong>organizations</strong><br />
through mediation is exempt from tax.<br />
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 80-279, 1980-2 C.B. 176.<br />
218.375 Environmental protection; litigation.<br />
An otherwise qualifying organization that<br />
was formed to protect and restore environmental<br />
quality and whose principal activity consists of<br />
instituting litigation as a party plaintiff to enforce<br />
environmental legislation is operated exclusively<br />
for charitable purposes and qualifies for exemption.<br />
§1.501(c)(3)–1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 80-278, 1980-2 C.B. 175.<br />
218.376 Equal job opportunities. A nonprofit<br />
organization formed to advance equal job opportunities<br />
for qualified workers discriminated<br />
against because of race or creed may qualify for<br />
exemption. §1.501(c)(3)–1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 68-70, 1968-1 C.B. 248.<br />
218.377 Equal rights; construction trade. A<br />
nonprofit organization formed to eliminate discrimination<br />
against members of minorities seeking<br />
employment in the construction trades by<br />
recruiting, educating, and counseling workers,<br />
providing technical assistance to attorneys<br />
involved in suits to enforce workers’ rights, and<br />
acting as court-appointed monitor after successful<br />
suits, is organized and operated exclusively for<br />
charitable and educational purposes.<br />
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 75-285, 1975-2 C.B. 203.<br />
218.378 Equal rights for women. An organization<br />
formed to promote equal rights for women by<br />
investigating instances of discrimination in<br />
employment and other economic opportunities<br />
and to aid women in recognizing and dealing with<br />
discrimination qualifies for exemption.<br />
§1.501(c)(3)-1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 72-228, 1972-1 C.B. 148.<br />
218.379 Evaluating scientific and medical literature.<br />
An organization formed to survey medical<br />
and scientific articles published throughout the<br />
world and to abstract selected articles of note in a<br />
monthly publication that is distributed free to<br />
interested parties requesting to be put on the mailing<br />
list is exempt from tax. §1.501(c)(3)–1. (Sec.<br />
501, ’86 Code.)<br />
Rev. Rul. 66-147, 1966-1 C.B. 137.<br />
218.380 Family controlled foundation. A<br />
foundation controlled by the creator’s family,<br />
operated to enable the creator and his family to<br />
engage in financial activities beneficial to them,<br />
results in the foundation’s ownership of non-income-producing<br />
assets which prevents its carrying<br />
on a charitable program commensurate in<br />
scope with its financial resources is not entitled to<br />
exemption. §1.501(c)(3)–1. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 67-5, 1967-1 C.B. 123.<br />
218.381 Farm bureaus; unrelated income. A<br />
county-wide organization engaged in the<br />
advancement and improvement of agriculture<br />
may be considered to be tax exempt. Any income<br />
it receives from the sale of supplies and equipment<br />
to members, however, is taxable as unrelated business<br />
income. (Sec. 501, ’86 Code.)<br />
Rev. Rul. 57-466, 1957-2 C.B. 311.<br />
218.382 Feeder <strong>organizations</strong> purchasing<br />
agency. A corporation, organized and operated for<br />
the primary purpose of operating and maintaining<br />
a purchasing agency for the benefit of its otherwise<br />
unrelated members who are exempt charitable<br />
<strong>organizations</strong>, is engaged in business activities<br />
which would be unrelated activities if carried on<br />
by any one of the tax-exempt <strong>organizations</strong><br />
served, and therefore, is not entitled to exemption.<br />
§39.101-2. (Sec. 101, ’39 Code; Sec. 501, ’86<br />
Code.)<br />
Rev. Rul. 54-305, 1954-2 C.B. 127.<br />
218.383 Film festival sponsorship. A nonprofit<br />
organization formed to promote the art of