Letter
2020 IRS Determinaton Letter and GR Memo
2020 IRS Determination Letter CURRENT and 2020 Group Ruling Memo FINAL
This memorandum explains the implications of the IRS's 2020 Group Ruling determination letter for Catholic organizations included in the USCCB Group Exemption (GEN 0928) and listed in the Official Catholic Directory (OCD). The ruling continues a series of annual IRS determinations dating back to 1946.
The memo serves as an annual compliance guide for Catholic institutions covered by the USCCB Group Ruling. It confirms their federal tax-exempt status and donor deductibility benefits while outlining key responsibilities regarding tax filings, public charity verification, employment taxes, school compliance, lobbying limits, and the absolute prohibition on political campaign intervention.
The Group Ruling confirms two major benefits for eligible Catholic entities:
- Federal tax-exempt status under Internal Revenue Code §501(c)(3).
- Deductibility of donations for federal income, gift, and estate tax purposes.
Repeal of the "Parking Lot Tax"
The Taxpayer Certainty and Disaster Relief Act of 2019 repealed the unrelated business income tax (UBIT) imposed on certain employer-provided parking and transportation benefits. The repeal was retroactive, allowing eligible organizations to seek refunds for taxes paid in 2018 and 2019.
Tax-Exempt Status
Organizations listed in the OCD and covered by the Group Ruling are recognized as tax-exempt charitable, educational, religious, and church-related organizations. Organizations marked with an asterisk in the OCD are not covered because they possess their own IRS determination letters.
Verifying Exemption
Many Group Ruling organizations do not appear in IRS online databases such as TEOS or donor services based on those databases. This does not affect their exempt status. Donors can verify eligibility through:
- The Official Catholic Directory.
- The USCCB.
- IRS Publication 4573 on group exemptions.
Public Charity Status
The memo confirms that covered organizations are public charities rather than private foundations, but not all share the same classification. Examples include:
- Churches, dioceses, parishes, and religious orders.
- Elementary and secondary schools, colleges, and universities.
- Hospitals.
Other Catholic nonprofits may need to provide documentation demonstrating their public-support status when applying for grants from foundations or donor-advised funds.