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VeOCOV <br /> � Office of the General Counsel <br /> 32 11 FOURTH STREET NE • WA:iHfNC,"ri7N DC 20011. 119 • 242-541 -3300 FAX 202454 t .3337 <br /> July 14, 2404 <br /> TO: Most Reverend Archbishops and Bishops , Diocesan Attorneys <br /> and State Conference Directors <br /> SUBJECT: 2004 Group Ruling <br /> FROM : Mark E . Chopko , General Counsel <br /> (Staff: Deirdre Dessingue, Associa a General Counsel ) <br /> Enclosed is a copy of the Group Ruling issued to the United States <br /> Conference of Catholic Bishops on July 1 , 2004 by the Internal Revenue Service <br /> ("IRS"), with respect to the federal tax status of Catholic organizations listed in the <br /> 2004 edition of the Official Catholic Directory (*OCD*)-V. As explained in greater <br /> detail below, this ruling is important for establishing : <br /> ( 1 ) the exemption of such organizations from: <br /> (a) federal income tax; <br /> (b) federal unemployment tax (but see 16 of <br /> "Explanation" below); and <br /> (2) the deductibility, for federal income , gift and estate tax <br /> purposes , of contributions to such organizations , <br /> The 2444 Group Ruling is the latest in a series that began with the original <br /> determination of March 25 , 1946 . in the 1946 document , the Treasury Department <br /> affirmed the exemption from federal income tax of all Catholic institutions listed In <br /> the OCD for that year. Each year since 1946 , in a separate letter, the 1946 ruling <br /> has been extended to cover the institutions listed in the current OCD?j. The <br /> language of these rulings has remained relatively unchanged , except to reflect <br /> intervening modifications in the Internal Revenue Code ("Code"). The 2004 Group <br /> Ruling is consistent with the 2003 ruling . <br /> Annual group rulings clarify important tax consequences for Catholic <br /> institutions listed in the OGD , and should be retained for ready reference. Rulings <br /> from earlier years are important to establish the tax consequences of transactions <br /> that occurred during those years . <br /> 1 A copy of the Group Ruling and this memo may be found on the USCCB website at <br /> war w, usccb. org/ogc. <br /> Catholic organizations with independent IRS exemption determination tetters are <br /> listen' in the 2004 OCD with an asterisk ( '); which is explained at page A-6 and <br /> indicates that such organizations are not covered by the Group Ruling. <br /> 2 <br />