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�V coN� r, o C lice o the General Counsel �, f �71 �� 3211 FOURTH STREET NE • WASHINGTON DC 20017- 1194 • 202-54 00 • FAX X3337_ _ IMPORTANT GROUP RULING INFORMATION 4 '� JUN 2 7 200P June 19, 2002 FOR THE INFORMATION OF: Most Reverend Archbishops an is ops , Diocesan Attorneys and Fiscal Managers , and State Conference Directors SUBJECT: 2002 Group Ruling FROM : Mark E . Chopko , General Counsel /A (Staff: Deirdre Dessingue , Associate General Counsel) Enclosed is a copy of the Group Ruling issued to the United States Conference of Catholic Bishops'-` on June 4, 2002 by the Internal Revenue Service ("IRS % with respect to the federal tax status of Catholic organizations listed in the 2002 edition of the Official Catholic Directory ("OCD")2 . As explained in greater detail below, this ruling is important for establishing : ( 1 ) the exemption of such organizations from : (a) federal income tax; (b) federal unemployment tax (but see ¶5 of "Explanation " below); and (2) the deductibility, for federal income , gift and estate tax purposes , of contributions to such organizations . The 2002 Group Ruling is the latest in a series that began with the original determination of March 25 , 1946 . In the 1946 document, the Treasury Department affirmed the exemption from federal income tax of all Catholic institutions listed in the OCD for that year. Each year since 1946 , in a separate letter, the 1946 ruling has been extended to cover the institutions listed in the current OCD-3'. The language of these rulings has remained relatively unchanged , except to reflect intervening modifications in the Internal Revenue Code ("Code"). The 2002 Group Ruling is consistent with the 2001 ruling . The name of the United States Catholic Conference was changed to the United States Conference of Catholic Bishops, effective July 1, 2001, 2 A copy of the Group Ruling may also be found on the USCC website at www. usccb. org/ogc. 3 Catholic organizations with independent IRS exemption determination letters are listed in the 2002 OCD with an asterisk (*), which is explained at page A- 11 and indicates that such organizations are not covered by the Group Ruling.