Letter
USCCB Letter to the IRS regarding IRS Notice 2020-36
Comments to IRS Notice 2020-36 submitted August 16, 2020
The United States Conference of Catholic Bishops (“USCCB”) is pleased to offer this comment letter regarding the IRS Notice referenced above and issued on May 1, 2020, which proposes a revenue procedure to modify and supersede Rev. Proc. 80-27, 1980-1 C.B. 677 (as modified by Rev. Proc. 96-40, 1996-2 C.B. 301).
Several of the provisions in the proposed revenue procedure would create significant problems for the USCCB group exemption, including the imposition of a substantial burden on governance and administration, as well as the religious exercises and practices, of the USCCB and its subordinate religious organizations.