Tax-Exempt Organizations: Information on Selected Types of Organizations
(Briefing Report, 02/28/95, GAO/GGD-95-84BR).
Since the mid-1970s, the number and the size of organizations that are
tax exempt have increased substantially; more than one million of these
organizations existed as of 1992. Press reports and congressional
hearings have recently focused on the activities of charitable groups,
but other kinds of tax-exempt organizations have not received this level
of scrutiny. This briefing report (1) discusses the growth in the
number, the assets, the revenues, and the expenses of social welfare
organizations, labor and agricultural groups, and business leagues; (2)
documents the compensation that some of the largest of these tax-exempt
organizations paid their executives in 1992; (3) identifies the extent
to which these organizations are involved in lobbying and political
activities; and (4) identifies Internal Revenue Service efforts to
monitor their activities. Information on charitable organizations is
presented for comparison purposes.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GGD-95-84BR
TITLE: Tax-Exempt Organizations: Information on Selected Types of
Organizations
DATE: 02/28/95
SUBJECT: Tax exempt organizations
Tax administration
Non-profit organizations
Lobbying activities
Executive compensation
Labor unions
Income statistics
Statistical data
Tax exempt status
Tax return audits
IDENTIFIER: IRS Exempt Organizations/Business Master File
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Cover
================================================================ COVER
Briefing Report to Congressional Requesters
February 1995
TAX-EXEMPT ORGANIZATIONS -
INFORMATION ON SELECTED TYPES OF
ORGANIZATIONS
GAO/GGD-95-84BR
Selected Tax-Exempt Organizations
(268639)
Abbreviations
=============================================================== ABBREV
COO - Chief Operating Officer
EIN - Employer Identification Number
EOBMF - Exempt Organization Business Master File
GDP - gross domestic product
IRC - Internal Revenue Code
UAW - International Union - United Auto, Aerospace, and
Agricultural Workers
Letter
=============================================================== LETTER
B-260138
February 28, 1995
The Honorable Byron L. Dorgan
United States Senate
The Honorable Harry Reid
United States Senate
Since the mid-1970s, the number and size of organizations that are
tax-exempt under Internal Revenue Code (IRC) section 501(c) have
increased substantially overall. As of 1992, there were over 1
million of these organizations in existence.\1
Press reports and congressional hearings have recently focused on the
activities of charitable organizations, but other types of tax-exempt
organizations have not received this level of scrutiny. As you
requested, we (1) determined the growth in the number, assets,
revenue, and expenses of social welfare organizations, labor and
agricultural organizations, and business leagues, (2) documented the
compensation that some of the largest of these tax-exempt
organizations paid their executives in 1992, (3) identified the
extent to which these organizations can be involved in lobbying and
political activities, and (4) identified IRS' efforts to monitor
their activities. Information concerning charitable organizations is
presented in this report for purposes of comparison.
On February 15, 1995, we briefed you and your staffs on the results
of our review. This report summarizes the information presented in
that briefing.
--------------------
\1 Appendix IV describes the types of organizations that are
tax-exempt under IRC section 501(c).
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
For the most part, the number and size of tax-exempt social welfare
organizations, labor and agricultural organizations, and business
leagues increased between 1975 and 1990. The changes over this
period are illustrated as follows:
-- The number of business leagues increased about 45 percent to
65,869, while the number of social welfare organizations
increased about 14 percent to 142,473. Conversely, the number
of labor and agricultural organizations declined about 18
percent to 71,653.
-- The assets (in 1990 dollars) of all three types of organizations
increased. Business leagues' assets increased more than 140
percent to over $19 billion, while those of labor and
agricultural organizations increased about 47 percent to nearly
$14 billion and those of social welfare organizations increased
about 20 percent to over $35 billion.
-- The change in revenue (in 1990 dollars) varied for these types
of organizations. While revenue for business leagues increased
nearly 144 percent to $18 billion and revenue for labor and
agricultural organizations increased about 13 percent to over
$12 billion, the revenue for social welfare organizations
declined almost 47 percent to $18 billion.
-- The change in expenses (in 1990 dollars) for these organizations
also varied. The expenses of business leagues increased about
145 percent to just over $18 billion and those of labor and
agricultural organizations increased nearly 19 percent to $12.7
billion. Meanwhile, the expenses of social welfare
organizations declined about 48 percent to $17.7 billion.
We analyzed the organizations' 1992 annual returns to determine the
compensation for the 5 highest paid executives from 46 of each of the
largest social welfare organizations, labor and agricultural
organizations, and business leagues, as measured by the
organizations' assets. Of 673 executives identified, we found that
100 executives (about 15 percent) received $200,000 or more in
compensation for 1992. Conversely, 198 executives (about 29 percent)
received no compensation for 1992.
IRS is responsible for monitoring the activities of tax-exempt
organizations through examinations of their annual returns. In
general, between 1990 and 1994 examinations of social welfare
organizations, labor and agricultural organizations, and business
leagues decreased about 30 percent, while the amount of taxes and
penalties resulting from these examinations increased about 200
percent. IRS also revoked the tax-exempt status of 67 of these types
of organizations between 1992 and 1994.
SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :2
To identify changes in the number, assets, income, and expenses of
tax-exempt organizations, we reviewed IRS annual reports and studies
by its Statistics of Income Division. To portray the changes in the
real value of the organizations' assets, income, and expenses, we
converted the financial information in these reports, which were
available for 1975 and 1990, to 1990 dollars.
To determine the compensation that executives received from social
welfare organizations, labor and agricultural organizations, and
business leagues, we obtained, and analyzed 285 IRS Form 990
returns--"Return of Organization Exempt From Income Tax"--filed by
some of the largest of these organizations for tax year 1992, the
most recent year available at the time of our review. A Form 990
return contains detailed information about an organization's assets,
revenue, and expenses, including the compensation paid to its
executives. The return must be filed annually with IRS by
organizations with gross receipts that exceed $25,000, and must be
made available to the public according to the IRC.
As agreed with you, we sought to obtain the Form 990 returns for tax
year 1992 from 50 of each of the largest social welfare organizations
and labor and agricultural organizations, as well as from 200 of the
largest business leagues. We identified these organizations on the
basis of the amount of their assets as recorded in an IRS Exempt
Organization Business Master File (EOBMF) containing all active
tax-exempt organizations as of March 31, 1994. Of the returns we
requested, we received and analyzed 46 returns of social welfare
organizations, 46 returns of labor and agricultural organizations,
and 193 returns of business leagues. IRS was unable to provide the
remaining returns at the time of our request. Appendix III lists
those organizations for which we received and analyzed a Form 990
return.
Our analysis included an in-depth review of the section of the
returns detailing the compensation that the organizations paid to
their executives, including officers, directors, and key employees.
We defined compensation to include salary; contributions to employee
benefit plans, including deferred compensation; and expense accounts
and other allowances\2 reported on the organizations' returns.
Appendix I lists the executives we identified who received $200,000
or more from these types of organizations. We also identified any
compensation that executives of these organizations received from
related organizations. Appendix II lists the executives we
identified who received compensation from related organizations.
To determine the rules governing lobbying and political activities
for these three types of organizations, as well as for charitable
organizations, we interviewed IRS Exempt Organization Division staff
and reviewed IRS guidelines, regulations, and the Internal Revenue
Code. To identify IRS' compliance efforts related to these
organizations, including the number of examinations, the taxes and
penalties that resulted from these examinations, and the number of
organizations for which IRS revoked their tax-exemption, we
interviewed IRS Exempt Organization Division staff and reviewed
Exempt Organization Division annual compliance reports.
We did our review from March 1994 through December 1994 at IRS'
national office in accordance with generally accepted government
auditing standards.
--------------------
\2 These include expense allowances or reimbursements that recipients
must report as income on their individual income tax returns.
AGENCY COMMENTS
------------------------------------------------------------ Letter :3
On February 7, 1995, we discussed a draft of this report with IRS
Exempt Organization Division officials at the national office. They
basically agreed with the information presented in the report and
provided some technical comments that were incorporated as
appropriate.
---------------------------------------------------------- Letter :3.1
As agreed with you, unless you announce the contents of this briefing
report earlier, we plan no further distribution of this report until
15 days from the date of this letter. At that time, we will send
copies of this report to various congressional committees, the
Commissioner of Internal Revenue, and other interested parties. We
will also make copies available to others upon request.
The major contributors to this report are listed in appendix V.
Please contact me at (202) 512-9044 if you or your staff have any
questions about this briefing report.
Natwar M. Gandhi
Associate Director, Tax Policy
and Administration
Briefing Section INFORMATION ON
SELECTED TYPES OF ORGANIZATIONS
============================================================== Letter
BACKGROUND ON TAX-EXEMPT
ORGANIZATIONS
------------------------------------------------------------ Letter :4
(See figure in printed
edition.)
Sources: IRS Statistics of
Income Division and Exempt
Organization Business Master
File.
(See figure in printed
edition.)
BACKGROUND INFORMATION ON
TAX-EXEMPT ORGANIZATIONS
---------------------------------------------------------- Letter :4.1
Internal Revenue Code (IRC) section 501(c) establishes 25 categories
of tax-exempt organizations that enjoy many benefits that for-profit
organizations do not. In particular, tax-exempt organizations are
required to pay federal income taxes only on unrelated business
income. They are also exempt from many state and local taxes. In
addition, contributions to charities are deductible from donors'
federal income taxes.
Charitable, religious, and educational organizations, tax-exempt
under IRC section 501(c)(3), and known collectively as charities, are
the largest category. In 1990, of a total of 1,022,223 tax-exempt
organizations,\1 charities represented 489,891 (48 percent). Social
welfare organizations represented the second largest category of
tax-exempt organization in 1990, totaling 142,473 (14 percent).
Labor and agricultural organizations ranked fourth, while business
leagues ranked fifth, with totals of 71,653 (7 percent) and 65,896
(about 6 percent), respectively. An additional 252,310 organizations
(about 25 percent) were exempt in 1990 under the remaining 21 IRC
501(c) categories.
Overall, tax-exempt organizations have grown in number and size since
the mid-1970s. Specifically, the total number of exempt
organizations has grown about 27 percent, from 806,375 organizations
in 1978 to more than 1 million in 1990. Between 1975 and 1990, the
assets of these organizations have grown in real terms over 150
percent to more than $1 trillion, and their revenues have grown over
225 percent to about $560 billion, while the growth in real gross
domestic product (GDP) for the United States was 52 percent. As of
1990, tax-exempt organizations accounted for approximately 10 percent
of GDP in terms of revenue, up from nearly 6 percent in 1975.
Charities alone accounted for about 7 percent of GDP in 1990.
This report focuses on social welfare organizations, labor and
agricultural organizations, and business leagues, which are
tax-exempt under IRC sections 501(c)(4), (5), and (6), respectively.
Specific information concerning charitable organizations has been
included for comparison purposes.
--------------------
\1 This total does not include certain 501(c)(3) religious
organizations that automatically qualify as tax-exempt and need not
apply to IRS for tax-exemption, as well as a small number of other
organizations that qualify as tax-exempt under other IRC sections.
SOCIAL WELFARE
ORGANIZATIONS--IRC 501(C)(4)
------------------------------------------------------------ Letter :5
(See figure in printed
edition.)
DEFINITION AND EXAMPLES OF
SOCIAL WELFARE ORGANIZATIONS
---------------------------------------------------------- Letter :5.1
Organizations operated and organized exclusively for the promotion of
social welfare, including civic leagues, as well as local
associations of employees--known collectively as social welfare
organizations--are exempt from federal income taxes under IRC section
501(c)(4). The net earnings of such organizations must be used
exclusively for charitable, educational, or recreational purposes.
An example of an organization operated for the promotion of social
welfare is the American Association of Retired Persons.\2 An example
of a local association of employees is the Minneapolis Police Relief
Association.
Social welfare organizations must promote the common good and general
welfare of the people of the community. Court rulings have further
required that a social welfare organization benefit a whole community
of people rather than a private group of citizens. For example, in
one case the court ruled that a nonprofit corporation formed to
acquire and operate a low-cost housing cooperative was not a
tax-exempt social welfare organization because, rather than offering
a service to the community-at-large, it only provided a service to
its members. However, an organization that benefits a private group
of citizens can be ruled tax-exempt if it can establish that it also
benefits the entire community. For example, IRS has ruled that an
organization engaged in the rehabilitation and job placement of its
members was tax-exempt because it benefited the community as a whole,
even though its membership was limited.
--------------------
\2 We selected examples of the largest IRC section 501(c)(4), (5),
and (6) organizations on the basis of their assets.
LABOR, AGRICULTURAL, AND
HORTICULTURAL ORGANIZATIONS--
IRC 501(C)(5)
------------------------------------------------------------ Letter :6
(See figure in printed
edition.)
DEFINITION AND EXAMPLES OF
LABOR, AGRICULTURAL, AND
HORTICULTURAL ORGANIZATIONS
---------------------------------------------------------- Letter :6.1
Labor, agricultural, and horticultural organizations--known
collectively as labor and agricultural organizations--are exempt from
federal income taxes under IRC section 501(c)(5). These
organizations must have one or more of the following objectives: (1)
bettering the conditions of persons engaged in the pursuits of labor,
agriculture, or horticulture, (2) improving the grade of their
products, or (3) developing a higher degree of efficiency in their
respective occupations. In addition, the net earnings of these
organizations may not inure to the benefit any of their members.\3
IRS defines a labor organization as an association of workers who
have combined to promote their interests by bargaining collectively
with their employers to secure better working conditions, wages, and
similar benefits. These organizations are generally composed of
employees or representatives of employees, but may also include
employers, self-employed persons, and independent contractors. They
may provide benefits to their members or members' families in the
event of a strike, lockout, death, accident, or similar occurrence.
An example of a labor organization is the International Union -
United Auto, Aerospace, and Agricultural Workers (UAW).
IRS uses the term agricultural to cover both agricultural and
horticultural organizations. IRS defines agriculture as the art or
science of cultivating the ground, including the preparation of the
soil, the planting of seeds, the raising and harvesting of crops, and
the rearing, feeding, and management of livestock, as well as the
harvesting of aquatic products. IRS defines horticulture as the
cultivation of a garden or orchard, as well as the art or science of
growing fruits, vegetables, flowers or ornamental plants. An example
of an agricultural organization is the Ohio Farm Bureau Federation,
Inc.
--------------------
\3 This prohibition generally states that a person can only receive
reasonable payment from an organization for goods and services
provided.
BUSINESS LEAGUES--IRC 501(C)(6)
------------------------------------------------------------ Letter :7
(See figure in printed
edition.)
DEFINITION AND EXAMPLES OF
BUSINESS LEAGUES
---------------------------------------------------------- Letter :7.1
Business leagues, chambers of commerce, real estate boards, boards of
trade, and professional football leagues--known collectively as
business leagues--are exempt from federal income taxes under IRC
section 501(c)(6). Business leagues cannot be organized for profit,
and no part of their net earnings can inure to the benefit of any
private shareholder or individual. Examples of business leagues
include the American Bureau of Shipping, the American Medical
Association, and the Chamber of Commerce of the U.S.A.
Treasury regulations define a business league as an association of
persons having a common business interest whose purpose is to promote
that interest. To qualify for tax-exempt status as a business
league, an organization cannot engage in a regular business of a kind
ordinarily carried on for profit, even if the business is operated on
a cooperative basis or produces only sufficient income to be
self-sustaining. Furthermore, the organization must work toward
improving the business conditions of one or more lines of business
rather than performing services for a particular business.
CHARITABLE, RELIGIOUS AND
EDUCATIONAL ORGANIZATIONS--IRC
501(C)(3)
------------------------------------------------------------ Letter :8
(See figure in printed
edition.)
DEFINITION AND EXAMPLES OF
CHARITIES
---------------------------------------------------------- Letter :8.1
Organizations operated and organized exclusively for charitable,
religious, scientific, testing for public safety, literary, or
educational purposes--known collectively as charities--are exempt
from federal income taxes under IRC section 501(c)(3). Charities
must benefit the general public as opposed to benefiting only private
individuals or groups. Some activities considered to be charitable
include (1) relieving the poor and distressed, (2) advancing religion
or education, (3) erecting or maintaining public buildings or
monuments, (4) lessening the burdens of government, and (5)
eliminating prejudice. Examples of charities are the Salvation Army,
the American Cancer Society, and Harvard University.\4
IRS staff use standards that have evolved over time from both IRS and
court rulings when determining whether an organization qualifies as a
tax-exempt charity. For example, IRS has determined that an
employment agency that operated exclusively to secure employment
without charge to the elderly qualified as a charity because it
provided services for a segment of the public with limited means.
Conversely, IRS has determined that a pharmaceutical service operated
by a nonprofit organization was not tax-exempt because, although it
provided discount pharmacy services to handicapped and senior
citizens, it also provided pharmacy services to the general public.
Furthermore, the pharmaceutical service did not provide free or below
cost drugs to the poor. As a result, IRS determined that the
pharmacy was not operated exclusively for charitable purposes because
it was primarily engaged in commercial activity.
--------------------
\4 We selected examples of charities on the basis of the largest
amount of charitable donations received.
NUMBER OF TAX-EXEMPT
ORGANIZATIONS (1978-1990)
------------------------------------------------------------ Letter :9
(See figure in printed
edition.)
Source: IRS Exempt
Organization Business Master
File.
(See figure in printed
edition.)
NUMBER OF TAX-EXEMPT
ORGANIZATIONS(1978-1990)\5
---------------------------------------------------------- Letter :9.1
Between 1978 and 1990, the total number of organizations exempt from
taxation under IRC section 501(c) increased from 806,375 to
1,022,223, an increase of about 27 percent. During this period, of
the three types of organizations that are the focus of this study,
business leagues increased the most, about 45 percent, from 45,325 in
1978 to 65,869 in 1990. Social welfare organizations increased
nearly 14 percent, from 125,317 in 1978 to 142,473 in 1990. Labor
and agricultural organizations declined about 18 percent, decreasing
from 87,531 in 1978 to 71,653 in 1990. By comparison, charities
increased nearly 67 percent, from 293,947 in 1978 to 489,891 in 1990,
while all other tax-exempt organizations combined decreased less than
1 percent, from 254,300 in 1978 to 252,300 in 1990.
--------------------
\5 Specific data on the number of exempt organizations was not
readily available prior to 1978.
ASSETS OF SELECTED TAX-EXEMPT
ORGANIZATIONS (1975-1990)
----------------------------------------------------------- Letter :10
(See figure in printed
edition.)
Source: IRS Statistics of
Income Division.
(See figure in printed
edition.)
ASSETS OF SELECTED
TAX-EXEMPT ORGANIZATIONS
(1975-1990)
--------------------------------------------------------- Letter :10.1
Business leagues' assets increased more percentage-wise than those of
social welfare organizations and labor and agricultural organizations
between 1975 and 1990, in 1990 dollars. Specifically, business
leagues' assets increased over 140 percent, from nearly $8 billion in
1975 to more than $19 billion in 1990. Labor and agricultural
organizations' assets increased about 47 percent during this period,
from $9.3 billion to $13.7 billion, although the total number of
these types of organizations declined. Social welfare organizations'
assets increased about 20 percent, from $29.3 billion in 1975 to
$35.1 billion in 1990.
Investments in securities comprised the single largest asset category
in 1990 for all three types of organizations, including social
welfare organizations ($7.4 billion), labor and agricultural
organizations ($4.6 billion), and business leagues ($6.2 billion).
REVENUES OF SELECTED TAX-EXEMPT
ORGANIZATIONS (1975-1990)
----------------------------------------------------------- Letter :11
(See figure in printed
edition.)
Source: IRS Statistics of
Income Division.
(See figure in printed
edition.)
REVENUES OF SELECTED
TAX-EXEMPT ORGANIZATIONS
(1975 TO 1990)
--------------------------------------------------------- Letter :11.1
The revenues of business leagues also increased more percentage-wise
than those of social welfare organizations or labor and agricultural
organizations between 1975 and 1990, in 1990 dollars. The revenues
of business leagues increased nearly 144 percent, from $7.4 billion
in 1975 to $18 billion in 1990. By contrast, the revenues of labor
and agricultural organizations increased about 13 percent during this
period, from $10.9 billion to $12.4 billion, while the revenues of
social welfare organizations declined about 47 percent, from $33.8
billion to $18 billion.
Revenues from program services and membership fees were the two
largest revenue sources for business leagues in 1990, totaling over
$7 billion each. Program services are the services provided in
carrying out the major objectives of a tax-exempt organization, such
as the publication of journals and newsletters. Labor and
agricultural organizations received most of their revenues in
1990--$7.3 billion--from membership fees, while social welfare
organizations received most of their revenues in 1990--$11.5
billion--from program services.
EXPENSES OF SELECTED TAX-EXEMPT
ORGANIZATIONS (1975-1990)
----------------------------------------------------------- Letter :12
(See figure in printed
edition.)
Source: IRS Statistics of
Income Division.
(See figure in printed
edition.)
EXPENSES OF SELECTED
TAX-EXEMPT ORGANIZATIONS
(1975-1990)
--------------------------------------------------------- Letter :12.1
The expenses of business leagues increased about 145 percent, from
$7.4 billion in 1975 to $18.2 in 1990, in 1990 dollars, while the
expenses of labor and agricultural organizations increased about 19
percent, from $10.6 billion to $12.7 billion. The expenses of social
welfare organizations declined about 48 percent, from $34.2 billion
in 1975 to $17.7 billion in 1990.
Benefits paid to or for members, at $5.7 billion, was the largest
expense item in 1990 for social welfare organizations, followed
closely by "other" expenses at $5.2 billion. "Other" expenses, which
included various items, such as advertising and consulting fees,
comprised the largest expense category in 1990 for both labor and
agricultural organizations and business leagues at $3.3 billion and
$7.7 billion, respectively. The second largest expense for these
organizations was salaries and wages at $2 billion and $2.9 billion,
respectively.
INUREMENT OF BENEFITS
----------------------------------------------------------- Letter :13
(See figure in printed
edition.)
INUREMENT OF BENEFITS
--------------------------------------------------------- Letter :13.1
The Internal Revenue Code prohibits the net earnings of business
leagues and charities from inuring to the benefit of any private
shareholder or individual, and Treasury regulation section
1.501(c)(5)-1(a)(1) establishes the same prohibition for labor and
agricultural organizations. For these organizations, inurement can
result in loss of their tax-exempt status. At the present time,
there is no similar prohibition for social welfare organizations.
This prohibition generally states that a person can only receive
reasonable payment from an organization for goods or services
provided. Specifically, inurement exists in several types of
circumstances where benefits, such as unreasonable compensation, low
or no-interest loans, and personal expenses, flow to an
organization's officers, directors, and other "insiders." While there
is no absolute measure of inurement, IRS and the courts assess
whether the compensation is reasonable for the services provided and
if compensation was agreed upon through arms length negotiations.
In a May 1994 report, the Subcommittee on Oversight of the House
Committee on Ways and Means concluded that IRS is not appropriately
enforcing the current prohibitions on inurement related to its
oversight of charities, and recommended that IRS be allowed to invoke
an intermediate sanction against any charity that engages in
activities resulting in inurement.
REASONABLE COMPENSATION
----------------------------------------------------------- Letter :14
(See figure in printed
edition.)
REASONABLE COMPENSATION
--------------------------------------------------------- Letter :14.1
One of IRS' primary measures of whether inurement has occurred is
whether compensation paid to an executive is reasonable. For-profit
businesses are allowed to deduct from their taxable income a
reasonable allowance for salaries or other compensation for personal
services rendered. This standard also has been applied to tax-exempt
organizations by the courts as one way to determine whether inurement
of benefits has taken place.
When deciding whether compensation is reasonable, IRS first must
determine the total amount of compensation paid by the organization.
Specifically, IRS considers the following to be compensation: (1)
salary or wages, (2) contributions to pension and profit sharing
plans, (3) unpaid deferred compensation, (4) payment of personal
expenses, (5) rents, royalties or fees, and (6) personal use of an
organization's property or facilities.
Once IRS determines the total amount of compensation, it then decides
whether the compensation is reasonable. IRS has no pre-set limit on
reasonable compensation, but judges reasonableness on a case-by-case
basis, as do the courts. For example, in one case the courts
determined that inurement existed when a college compensated an
executive according to a formula based on stock ownership, rather
than paying a reasonable amount for services rendered. In another
case, IRS determined that a hospital's contract to pay a radiologist
a percentage of the gross receipts of the radiology department did
not constitute inurement because the agreement was reached through
arms length bargaining and the radiologist had no controlling
interest in the hospital.
The primary way IRS determines reasonableness is a comparison of
compensation paid by similar organizations. IRS also considers the
salary history of the individual, his or her responsibilities, the
salary scale of employees in general, and the amount of control the
individual has in determining his or her own salary.
EXECUTIVE COMPENSATION PAID BY
SELECTED ORGANIZATIONS (1992)
----------------------------------------------------------- Letter :15
(See figure in printed
edition.)
Source: GAO analysis of IRS
data.
(See figure in printed
edition.)
EXECUTIVE COMPENSATION PAID
BY SELECTED TAX-EXEMPT
ORGANIZATIONS (1992)\6
--------------------------------------------------------- Letter :15.1
In 1992, about 62 percent of the highest paid executives of 46 of
each of the largest social welfare organizations, labor and
agricultural organizations, and business leagues received less than
$100,000 in compensation, while nearly 15 percent received $200,000
or more. Specifically, out of a total of 673 executives, including
officers, directors, and key employees, identified on the annual
returns these organizations filed with IRS, 198 (about 29 percent)
received no compensation, 218 (about 32 percent) received from $1 to
$100,000, and 157 (about 23 percent) received from $100,000 to
$200,000. There were also 100 executives (about 15 percent) who
received more than $200,000 in compensation.
Business leagues had both the largest number of executives receiving
no compensation as well as those receiving more than $200,000, with
90 and 44, respectively. Labor organizations had the most executives
making between $100,000 and $200,000 with 73, while social welfare
organizations had the most executives making between $0 and $100,000
with 87.
Of the organizations we reviewed, The PGA Tour, Inc., a business
league, paid the highest overall 1992 executive compensation ($4.1
million) to its Commissioner.\7 The highest compensated executive of
a social welfare organization was the Chairman, President, and Chief
Executive Officer of the Mutual of America Life Insurance Company who
received $1.2 million. The highest compensated officer of a labor or
agricultural organization was the Executive Director of the Major
League Baseball Players Association who received over $900,000.
--------------------
\6 Our compensation figures include all salary, benefits, including
deferred compensation, and expense account items that an employee is
required to claim on his or her individual income tax return, such as
the value of housing, automobiles or other assets owned or leased by
the organization. Although our compensation figures are for 1 year,
compensation may vary from year to year.
\7 The examples are presented to illustrate the range of salaries
paid by these organizations to their executives. We did not attempt
to determine whether or not the compensation was reasonable.
RELATED ORGANIZATIONS
----------------------------------------------------------- Letter :16
(See figure in printed
edition.)
RELATED ORGANIZATIONS
--------------------------------------------------------- Letter :16.1
A tax-exempt organization may be related to another organization that
may be either a tax-exempt or taxable entity. For example, a social
welfare organization might establish a tax-exempt charitable
affiliate to receive tax deductible contributions, so long as their
records show that their finances are kept separate. Conversely, a
charitable organization could establish a social welfare organization
to carry out lobbying and political activities, so long as the two
organizations are separately incorporated, and they can document that
contributions made to the charitable organization are not provided to
the social welfare organization.
Executives, such as directors and officers, may serve and be
compensated by related organizations. Each organization is required
to describe its program and financial activities, including any
transactions with related organizations, in its annual return filed
with IRS. This includes any compensation paid to an executive by a
related organization, provided the executive's total compensation is
more than $100,000, of which more than $10,000 was provided by the
related organization.
Of the 285 organizations we reviewed, 29 reported that their
executives met these criteria. The amounts of total related
compensation paid to these executives ranged from $12,320 to $711,807
(see app. II).
LOBBYING AND POLITICAL
ACTIVITIES
----------------------------------------------------------- Letter :17
(See figure in printed
edition.)
LOBBYING AND POLITICAL
ACTIVITIES
--------------------------------------------------------- Letter :17.1
Lobbying activity involves an attempt to influence legislation
through such means as contacting or urging the public to contact a
member or employee of a legislative body, or a government official or
employee of an executive agency who is in a position to propose,
support, oppose, or reject legislation. "Grass-roots" lobbying is an
attempt to influence the opinion of the general public concerning
legislation.
Lobbying activity is permitted for social welfare organizations,
labor and agricultural organizations, and business leagues and can be
the primary activity of these types of organizations, providing it
relates to their tax-exempt purposes. Certain charities may spend up
to a maximum of $1 million annually on lobbying activities, provided
that no more than 25 percent of the lobbying expenditures involves
"grass-roots" lobbying. Charities that do not elect this lobbying
limit may not engage in substantial lobbying activity.
Political activity involves participating or intervening in a
political campaign on behalf of or in opposition to a candidate for
public office. This type of activity includes the publication or
distribution of printed statements and the making of oral statements
favoring one candidate over another.\8
Social welfare organizations, labor and agricultural organizations,
and business leagues can engage in political activity, provided it is
not the organizations' primary activity. For charities, political
activity is generally prohibited. However, nonpartisan voter
education, such as disseminating the overall voting record of Members
of Congress pertaining to a variety of issues or conducting a
"get-out-the-vote" drive, is a permissible activity.
--------------------
\8 Tax-exempt organizations may establish separate segregated funds
for conducting political activities. Such funds, established under
IRC section 527, are tax-exempt as "political organizations" provided
contributions to the fund are used primarily for political purposes.
Due to the strict limitations related to the political activity of
charities imposed by IRC section 501(c)(3), a separate segregated
fund established by a charity may not be used for political campaign
involvement, such as influencing the election of a public official.
Social welfare organizations, labor and agricultural organizations,
and business leagues have no such limitation.
TAX DEDUCTIBILITY OF
CONTRIBUTIONS, DUES AND
MEMBERSHIP FEES
----------------------------------------------------------- Letter :18
(See figure in printed
edition.)
DEDUCTIBILITY OF
CONTRIBUTIONS, DUES, AND
MEMBERSHIP FEES PAID TO
TAX-EXEMPT ORGANIZATIONS
--------------------------------------------------------- Letter :18.1
One of the benefits of tax-exempt status is the deductibility of
contributions, dues, and membership fees to taxpayers who provide
such sources of revenue to tax-exempt organizations. This enables
these organizations to raise some of the revenue needed to carry out
their tax-exempt purpose.
Contributions to social welfare, labor and agricultural
organizations, and business leagues are not tax deductible. Dues and
membership fees paid to these organizations are deductible as a
business expense, if they are ordinary and necessary for conducting
the payor's business. However, the organizations must inform the
contributors if any portion of such dues and membership fees is to be
used for lobbying, because that portion is not tax deductible to the
payors.
Contributions made to charities are tax deductible to the
contributors, provided the contributions are not "earmarked" for
either political activities or lobbying. Dues and membership fees
paid to charities are tax deductible only to the extent that the
amount paid is more than the value of any benefits received by the
payor.
PROCESS FOR OBTAINING
TAX-EXEMPT STATUS
----------------------------------------------------------- Letter :19
(See figure in printed
edition.)
An organization must apply for tax-exempt status to the IRS district
office responsible for the geographic location in which the
organization maintains its principal place of business.\9 When
applying, the organization must submit the following to IRS: (1) a
signed application form; (2) an IRS Form 8718, "User Fee for Exempt
Organization Determination Letter Request" with the appropriate user
fee; (3) IRS Form SS-4, "Application for Employer Identification
Number" (EIN) if the organization does not have an EIN; (4) various
organizational documents, such as its Articles of Incorporation; (5)
a narrative statement of past, present, and proposed activities; and
(6) a proposed budget for 2 years for organizations with less than 1
year of operations, and (7) a statement of receipts and expenditures
for the current and 3 preceding years, and a balance sheet for the
most recent period for ongoing organizations.
IRS district office staff are to review the application package for
completeness and determine whether the organization qualifies for tax
exemption. If, during the initial screening IRS staff determine that
the application package is incomplete, they are to contact the
organization to obtain the missing information. Once the application
is complete, IRS staff are to conduct a technical screening to
determine if the application needs to be reviewed by an Exempt
Organization specialist. In general, these specialists review
applications that involve unusual circumstances, controversial
issues, or contain voluminous attachments. If the specialist has
concerns not specifically covered by statute, regulation, Treasury
decision, or a ruling published in the Internal Revenue Bulletin, the
application must be forwarded to IRS National Office staff for
further review. Once the application review has been completed, IRS
is to notify the organization with a determination letter.
IRS reviewed more than 57,000 applications for tax exemption in 1992.
Of these, IRS approved nearly 44,000 (77 percent) and denied nearly
1,000 (2 percent). An additional 12,000 (21 percent) applications
were neither approved nor denied because the organizations either
withdrew their application or failed to provide the additional
information requested by IRS.
--------------------
\9 In the near future, IRS plans to consolidate its process for
determining the tax-exempt status of organizations in one "key"
district office.
IRS EXAMINATIONS OF TAX-EXEMPT
ORGANIZATIONS (FY90-94)
----------------------------------------------------------- Letter :20
(See figure in printed
edition.)
Source: IRS Exempt
Organization Division.
(See figure in printed
edition.)
IRS EXAMINATIONS OF SELECTED
TAX-EXEMPT ORGANIZATIONS
(FY90- FY94)
--------------------------------------------------------- Letter :20.1
Between fiscal years 1990 and 1994, the number of IRS' examinations
decreased substantially for both social welfare organizations and
business leagues, and increased slightly for labor and agricultural
organizations. Specifically, examinations of social welfare
organizations decreased from 816 in fiscal year 1990 to 397 in fiscal
year 1994. During this same period the number of examinations of
business leagues decreased from 1500 to 874. Meanwhile, the
examinations of labor and agricultural organizations initially
decreased from 764 in fiscal year 1990 to 560 in fiscal year 1992,
but then subsequently increased to 828 in fiscal year 1994.
We did not attempt to determine the adequacy of IRS' efforts to
monitor the activities of these organizations. However, in its May
1994 report, the Subcommittee on Oversight of the House Committee on
Ways and Means recommended that IRS increase both the staffing and
funding levels allocated for exempt organization examination and
compliance activities, particularly related to charities.
TAXES AND PENALTIES ASSESSED
AGAINST EXEMPT ORGS. (FY90-94)
----------------------------------------------------------- Letter :21
(See figure in printed
edition.)
Source: IRS Exempt
Organization Division.
(See figure in printed
edition.)
TAXES AND PENALTIES ASSESSED
AGAINST SELECTED TAX-EXEMPT
ORGANIZATIONS (FY90-FY94)
--------------------------------------------------------- Letter :21.1
While the combined number of examinations of social welfare
organizations, labor and agricultural organizations, and business
leagues has declined from fiscal year 1990 to fiscal year 1994, the
taxes and penalties assessed against these organizations increased
greatly during this period. For example, the taxes and penalties
assessed against social welfare organizations increased from $484,554
in fiscal year 1990 to over $138 million in fiscal year 1994. During
this period, taxes and penalties assessed against labor and
agricultural organizations increased from about $2.4 million in
fiscal year 1990 to nearly $20 million in fiscal year 1994, while
taxes and penalties assessed against business leagues decreased from
nearly $4.2 million to just over $1.1 million. A majority of these
assessments resulted from examinations of IRS Form 990T, "Exempt
Organization Business Income Tax Return."\10
--------------------
\10 Tax exempt organizations must file a separate return and pay
income taxes on income over $1,000 that they receive as a result of
activities that are not related to their exempt purpose.
NUMBER OF REVOCATIONS OF
TAX-EXEMPT STATUS (FY92-94)
----------------------------------------------------------- Letter :22
(See figure in printed
edition.)
Source: IRS Exempt
Organizations Division.
(See figure in printed
edition.)
REVOCATIONS OF TAX-EXEMPTION
FOR SELECTED ORGANIZATIONS
(FY92- FY94)
--------------------------------------------------------- Letter :22.1
Between fiscal year 1992 and fiscal year 1994, IRS revoked the
tax-exemptions of a combined 67 social welfare organizations, labor
and agricultural organizations, and business leagues.\11 IRS revoked
the tax exemption of 34 social welfare organizations, 31 business
leagues, and 2 labor organizations during this 3-year period. IRS
was unable to provide us with the specific reasons for these
revocations.
In its May 1994 report, the Subcommittee on Oversight recommended
that IRS be required to disclose the reasons for revoking an
organization's tax-exempt status. At present, IRS is only required
to disclose the name of charities that have had their tax-exemption
revoked.
--------------------
\11 IRS could not provide specific data concerning revocations prior
to FY 92.
EXECUTIVES OF SELECTED TAX-EXEMPT
ORGANIZATIONS WHO WERE COMPENSATED
$200,000 OR MORE IN 1992
=========================================================== Appendix I
Compensati
Organization Title on
---------------------------- ---------------------------- ----------
Social welfare organizations
----------------------------------------------------------------------
American Association of Executive Director $323,537
Retired Persons
AVMED, Inc. President/Director 235,459
Senior Vice-President/ 205,390
Director
Blue Cross Blue Shield President and Chief 777,947
Association Executive Officer
Executive Vice-President and 413,091
Chief Operating Officer
(COO)
Senior Vice-President 221,929
Senior Vice-President 210,589
Senior Vice-President 200,960
Connecticare Executive Vice-President and 282,794
Chief Medical Officer
President and Chief 216,845
Executive Officer
Higher Education Assistance President 220,452
Foundation
Independent Health President 316,464
Association, Inc.
Executive Vice-President 251,865
Marine Spill Response President 244,679
Corporation
Vice-President-Operations/ 211,137
General Manager
Midwest Foundation Chief Executive Officer 380,718
Independent Physicians
Association
Chief Medical Officer 241,995
Mutual of America Life Chairman, President and 1,209,573
Insurance Company Chief Executive Officer
Senior Executive Vice- 328,173
President and Chief
Financial Officer
President and COO 322,338
Executive Vice-President/ 313,931
Chief Investment Officer
Executive Vice-President- 287,455
External Affairs
Tufts Associated Health President 428,887
Maintenance Organization
None Given 357,106
None Given 314,211
None Given 233,810
Washington Dental Service Executive Director 296,378
Labor and agricultural organizations
----------------------------------------------------------------------
Air Line Pilots Association President 345,522
American Federation of President 260,004
State, County and Municipal
Employees (AFSCME)
Secretary/Treasurer 222,965
American Federation of President 209,045
Teachers, AFL-CIO
Directors Guild of America Executive Director 420,627
International Longshoremens President 272,069
Secretary/Treasurer 245,494
Executive Vice-President 233,354
International Union of General President 223,897
Operating Engineers
Laborers International Union General President 318,827
of North America
Second Vice-President 232,436
First Vice-President 225,928
General Secretary/Treasurer 218,149
Seventh Vice-President 214,264
Local 32B-32J Service President 267,119
Employees International
Union
Major League Baseball Executive Director-Legal 931,578
Players Association Counsel
Michigan Education Executive Director 220,632
Association
National Education President 221,712
Association of US, Inc.
New York City District Executive Director 216,858
Council 37, AFSCME, AFL-
CIO
Treasurer 202,749
Screen Actors Guild, Inc. National Executive Director 318,007
Assistant National Executive 277,706
Director
Service Employees President 203,080
International Union
United Brotherhood of General President 219,136
Carpenters and Joiners of
America
United Food and Commercial President 293,992
Workers International Union
Secretary/Treasurer 211,337
United Transportation Union Vice-President 285,903
Vice-President 277,105
President 214,927
Business leagues
----------------------------------------------------------------------
AIPSO President 275,713
Air Transport Association of President 230,603
America
American Bankers Association Executive Vice-President 489,951
American Bar Association Executive Director 230,525
American Board of Family Executive Director 381,305
Practice
American College of Executive Director 270,625
Emergency Physicians
American Dental Association Executive Director 215,850
American Gas Association President 343,780
Senior Vice-President 207,667
Senior Vice-President 203,125
American Hardware President, Chief Executive 373,588
Manufacturing Association Officer and Secretary
American Health Care Executive Vice-President 310,059
Association
American Hospital President 536,200
Association
Senior Vice-President 258,766
Secretary/Treasurer 244,636
Executive Vice-President 238,540
Senior Vice President 213,859
American Institute of Executive Vice-President/ 303,787
Architects Chief Executive Officer
American Institute of President 512,947
Certified Public
Accountants
Counsel and Secretary 263,195
American Insurance President 616,176
Association Inc.
Senior Vice-President 260,065
Senior Vice-President and 242,569
General Counsel
Senior Vice-President 230,782
American Medical Association Executive Vice-President 486,910
President-Elect 329,607
President 298,240
Immediate Past-President 220,070
American Petroleum Institute President 742,111
Senior Vice-President 282,393
Vice-President 215,108
Vice-President 213,440
Vice-President 205,387
American Pharmaceutical Executive Vice-President 336,849
Association
American Physical Therapy Executive Vice-President 259,614
Association
American Society of President 430,043
Association Executives
American Society of Hospital Executive Vice-President 458,773
Pharmacists
American Trucking President 295,750
Association, Inc.
AMT -The Association For President 346,047
Manufacturing Technology
Association of American President and Chief 488,188
Railroads Executive Officer
Vice-President and General 288,065
Counsel
Executive Vice-President 274,393
ATP Tour, Inc. Chief Executive Officer 871,321
Audio Digest Foundation Vice-President 207,400
Bank Administration President/Chief Executive 245,000
Institute Officer
Breeders' Cup Limited Executive Director 209,053
President 203,077
Cable Television Labs, Inc. President/Chief Executive 394,038
Officer
Vice-President/COO 385,004
California Association of President 432,998
Hospitals and Health
Systems
California Association of Chief Executive 250,866
Realtors
Vice-President 206,145
California Dental Executive Director 225,443
Association
Chamber of Commerce of the President 452,704
U.S.A.
Senior Vice-President/ 220,877
Secretary
Senior Vice-President 220,877
Senior Vice-President 220,329
Chemical Industry Institute President 278,848
of Toxicology
Cosmetic Toiletry and President 542,137
Fragrance Association
Credit Union National President 304,728
Association, Inc.
Edison Electric Institute President 272,970
General Counsel and 213,649
Executive Vice-President
Electronic Industries President 475,063
Association
Group Vice-President 201,096
Food Marketing Institute President 1,559,305
Senior Vice-President 254,429
Senior Vice-President 229,470
Greater Seattle Chamber of President 211,909
Commerce
Health Insurance Association President 422,307
of America
Vice-President 261,542
Vice-President 211,379
Vice-President 208,553
Vice-President 201,846
Illinois Hospital President 283,858
Association
Senior Vice-President 219,404
Independent Bankers Executive Vice-President 218,728
Association of America
Institute of Electrical and Executive Director 255,993
Electronics Engineers
International Council of Executive Vice-President 539,681
Shopping Centers, Inc.
Investment Company Institute President 619,602
Executive Vice-President 353,698
Senior Vice-President- 299,539
Legislative Affairs
Vice-President-Tax and 230,361
Pension
Motion Picture Association President and Chief 816,368
of America Executive Officer
Executive Vice-President and 606,115
COO
NASDAQ, Inc. President 214,378
National Academy of President 612,386
Recording Arts and
Sciences, Inc.
National Association of President 634,426
Chain Drug Stores
Vice-President-Pharmacy 269,408
National Association of President 212,884
Convenience Stores
National Association of None Given 280,360
Professional Insurance
Agents
National Association of Executive Vice-President 438,340
Realtors
National Association of President and Chief 431,178
Securities Dealers, Inc. Executive Officer
Vice-President 202,072
National Council on President 445,580
Compensation Insurance
COO 317,772
Senior Vice-President-Rates 227,256
and External Affairs
Senior Vice-President- 200,328
Information Resource
National Electrical President 214,143
Manufacturers Association
National Hot Rod Association President 335,000
National Institute for President 227,925
Automotive Service
Excellence
National Rural Electric Executive Vice-President 233,777
Cooperative
National Soft Drink President 503,798
Association
National Solid Wastes Executive Director/Chief 321,090
Management Association Executive Officer
National Telephone Executive Director 232,300
Cooperative Association
National Wholesale Past Executive Director 589,149
Druggists' Association
New York Shipping President 230,550
Association, Inc.
Newspaper Association of President and Chief 815,719
America Executive Officer
Executive Vice-President and 309,361
COO
Open Software Foundation President 1,461,569
Treasurer 914,216
Secretary 267,299
PGA Tour, Inc. Commissioner 4,103,493
Deputy Commissioner/COO 693,335
Executive Vice-President - 528,580
Marketing
Executive Vice-President- 383,644
Counsel
Executive Vice-President 344,866
Portland Cement Association President 301,324
Public Securities President and Secretary 320,424
Association
Executive Vice-President 266,613
Senior Vice-President and 208,607
General Counsel
Savings and Community Former President 310,508
Bankers of America
Savings Banks Life Insurance President (Retired) 213,463
Fund
Semiconductor Equipment and President 294,812
Materials International
Semiconductor Research President 272,981
Corporation
Sheet Metal and Air Executive Vice-President 232,310
Conditioning Contractors'
National Association
Society for Human Resource President/Chief Executive 334,080
Management Officer
Texas Medical Association Executive Vice-President 225,277
The Association of Trial Executive Director 243,408
Lawyers of America
The Council for Tobacco Chairman/President 340,634
Research -USA, Inc.
The Hospital Association of President 239,241
Pennsylvania
Senior Vice-President 207,759
The National Association of Executive Vice-President 586,026
Life Underwriters
Senior Vice-President- 208,145
General Counsel
The Professional Golfers' Chief Executive Officer 386,788
Association of America
The Society of the Plastics President 290,637
Industry, Inc.
----------------------------------------------------------------------
Source: GAO analysis of IRS data.
EXECUTIVES OF SELECTED TAX-EXEMPT
ORGANIZATIONS WHO RECEIVED
COMPENSATION FROM RELATED
ORGANIZATIONS IN 1992
========================================================== Appendix II
Organization (related
organization) Title Compensation
------------------------ ------------------------ ------------------
Social welfare organizations
----------------------------------------------------------------------
Higher Education Loan Chairman of the Board $49,700
Program (HELP) of and Director
Kansas
HELP Management 149,100
Corporation
HELP America Inc. 12,400
HELP D.C. Inc. 24,800
HELP W.V. Inc. 12,400
======================================================================
Total $248,400
Higher Education Loan President/Secretary/ 31,600
Program (HELP) of Treasurer
Kansas
HELP Management 52,800
Corporation
HELP Management 15,500
Corporation
HELP W.V. Inc. 5,400
======================================================================
Total $105,300
AVMED, Inc. President/Director 235,459
Santafe Management 16,011
Services, Inc.
Alachua General 35,676
Hospital, Inc.
======================================================================
Total $287,146
AVMED, Inc. Executive Vice 147,812
President/Director
Wellness, Inc. 3,650
Santafe Medical 3,650
Services, Inc.
Alachua General 12,744
Hospital, Inc.
Bradford Hospital, Inc. 3,650
Suwannee Hospital, Inc. 1,825
Lake Shore Hospital, 5,475
Inc.
North Central Florida 3,650
Rehabilitation, Inc.
Santafe Management 1,113
Services, Inc.
======================================================================
Total $183,599
Henry Ford Health Care President $0
Corporation Self-
Funded Liability Plan
Henry Ford Health System 700,900
======================================================================
Total $700,900
Henry Ford Health Care Trustee 0
Corporation
Self-Funded Liability
Plan
Henry Ford Health System 488,108
======================================================================
Total $ 488,108
Henry Ford Health Care Treasurer 0
Corporation Self-
Funded Liability Plan
Henry Ford Health System 395,601
======================================================================
Total $395,601
Henry Ford Health Care Trustee 0
Corporation Self-
Funded Liability Plan
Henry Ford Health System 263,210
======================================================================
Total $263,210
Henry Ford Health Care Trustee 0
Corporation Self-
Funded Liability Plan
Henry Ford Health System 212,525
======================================================================
Total $212,525
Labor and Agricultural Organizations
----------------------------------------------------------------------
International General Secretary- 187,617
Brotherhood of Treasurer
Teamsters
Teamsters Local Union 12,320
No.30
======================================================================
Total $199,937
International Vice President- 166,564
Brotherhood of International
Teamsters Representative
Teamsters Local Union 57,684
No. 1999
Canadian Conference of 78,289
Teamsters
======================================================================
Total $302,537
International Vice President- 84,523
Brotherhood of International
Teamsters Representative
Teamsters Local Union 85,566
No. 938
Canadian Conference of 19,100
Teamsters
======================================================================
Total $189,189
District 37 Benefits Chairman of the Board $ 0
Fund Trust
AFSCME District Council 224,301
37
======================================================================
Total $224,301
District 37 Benefits Trustee 0
Fund Trust
AFSCME District Council 210,016
37
======================================================================
Total $ 210,016
District 37 Benefits Trustee 0
Fund Trust
AFSCME District Council 184,408
37
======================================================================
Total $184,408
Seafarers Harry Lundberg Trustee 0
School of Seamanship
Seafarers International 68,977
Union of North America
United Industrial 40,000
Workers, Services,
Transportation,
Professional, and
Government of North
America
Seafarers Building 24,923
Corporation
======================================================================
Total $133,900
Joint Employment Administrator 5,323
Committee
MEBA Medical and 140,540
Benefits Plan
======================================================================
Total $145,863
Business Leagues
----------------------------------------------------------------------
National Association of President and Chief 431,178
Securities Dealers, Executive Officer
Inc.
NASD Market Services, 214,378
Inc.
NASDAQ, Inc. 214,378
======================================================================
Total $859,934
National Association of Executive Vice President 181,133
Securities Dealers,
Inc.
NASD Market Services, 90,566
Inc.
NASDAQ, Inc. 90,566
======================================================================
Total $362,265
PGA Tour, Inc. Commissioner $4,103,493
PGA Tour Golf Course 711,807
Properties, Inc.
======================================================================
Total $4,815,300
PGA Tour, Inc. Deputy Commissioner/COO 693,335
PGA Tour Golf Course 676,512
Properties, Inc.
======================================================================
Total $1,369,847
PGA Tour, Inc. Executive Vice 383,644
President/Counsel
PGA Tour Golf Course 159,420
Properties, Inc.
======================================================================
Total $543,064
The Hospital Association President 239,241
of Pennsylvania
PHICO Group, Inc. 83,750
======================================================================
Total $322,991
NASDAQ, Inc. President 214,378
NASD Market Services, 214,378
Inc.
National Association of 428,760
Securities Dealers,
Inc.
======================================================================
Total $857,516
NASDAQ, Inc. Senior Vice President 92,367
NASD Market Services, 75,401
Inc.
National Association of 20,734
Securities Dealers,
Inc.
======================================================================
Total $188,502
NASDAQ, Inc. Executive Vice President 90,566
NASD Market Services, 90,566
Inc.
National Association of 181,133
Securities Dealers,
Inc.
======================================================================
Total $362,265
NASDAQ, Inc. Executive Vice President 84,710
NASD Market Services, 84,710
Inc.
National Association of 169,422
Securities Dealers,
Inc.
======================================================================
Total $388,842
New Jersey Hospital President 142,871
Association
Center for Health 214,089
Affairs Inc.
======================================================================
Total $356,960
New Jersey Hospital Treasurer 0
Association
Center for Health 180,457
Affairs Inc.
======================================================================
Total $180,457
New Jersey Hospital Secretary 0
Association
Center for Health 169,309
Affairs Inc.
======================================================================
Total $169.309
National Automobile Executive Vice President 163,586
Dealers Association
NADA Services 104,264
Corporation
======================================================================
Total $267,850
National Automobile Assistant Secretary 72,011
Dealers Association
NADA Services 58,918
Corporation
======================================================================
Total $130,929
American Trucking President 295,750
Association, Inc.
ATA Litigation Center 45,500
ATA Foundation 45,500
Deliver USA 22,750
ATA Services, Inc. 22,750
Trucking Information 22,750
Services
======================================================================
Total $455,000
California League of President 79,823
Savings Institutions
California League 25,207
Financial Services,
Inc.
======================================================================
Total $105,030
National Wholesale President 157,611
Druggists' Association
NWDA Service Corp. 22,370
======================================================================
Total $179,981
American Insurance President 616,176
Association, Inc.
American Insurance 331,788
Services Group, Inc.
======================================================================
Total $947,964
American Insurance Senior Vice-President $186,154
Association, Inc. and COO
American Insurance 124,104
Services Group, Inc.
======================================================================
Total $310,258
----------------------------------------------------------------------
Note: This table includes only the top five executives of these
organizations who received compensation from related organizations.
Source: GAO analysis of IRS data.
ASSETS, REVENUES AND EXPENSES OF
THE TAX-EXEMPT ORGANIZATIONS
INCLUDED IN THIS STUDY
========================================================= Appendix III
(Dollars in thousands)
Name of organization Assets Revenues Expenses
---------------------------------------- -------- -------- --------
Social welfare organizations
----------------------------------------------------------------------
American Association of Retired Persons $330,638 $292,264 $310,763
AVMED, Inc. 98,346 310,256 288,561
Bank of Sweden Tercentenary Foundation 284,429 20,988 14,371
Blue Care Network of Southeast Michigan 132,446 173,845 158,686
Blue Care Network-Great Lakes 54,598 172,034 169,729
Blue Cross Blue Shield Association 134,320 133,381 131,159
California Vision Service 143,754 304,224 299,865
Capital District Physicians' Health 69,372 164,166 151,289
Plan, Inc.
City of Mesa-Municipal Development 50,152 3,101 2,339
Corporation
City of Scottsdale Municipal Property 203,588 41,913 15,178
Corporation
Columbus Multi-School Building 57,291 1,653 3,316
Corporation
Connecticare 60,906 190,645 187,197
County of Riverside Asset Leasing 580,280 34,651 29,879
Corporation
CSDA Finance Corporation 274,390 19,787 19,730
Delta Dental Plan of Michigan, Inc. 148,660 401,729 399,206
Delta Dental Plan of New Jersey, Inc. 67,113 130,564 122,605
Disabled American Veterans 144,832 70,995 68,854
Firemen's Association of the State of 66,710 9,549 5,610
New York
Firemens Relief Associations of 52,968 3,403 1,419
Minnesota
Group Health Association 82,704 251,817 248,624
Henry Ford Health Care Corporation 55,565 23,345 21,712
Liability Fund
Higher Education Assistance Foundation 216,210 172,588 62,703
Higher Education Loan Program of Kansas, 235,523 14,972 10,969
Inc.
Independent Health Association, Inc. 83,935 252,288 244,398
International Olympic Committee 127,121 18,122 22,696
JADER Trust 101,133 6,194 4,060
Luso-American Development Foundation 130,327 24,890 15,188
Marine Spill Response Corporation 264,818 84,610 72,888
Medcenters Health Care, Inc. 102,899 352,189 349,834
Merrillville Multi-School Building 117,269 3,304 5,773
Corporation
Midwest Foundation Independent 110,063 225,844 213,056
Physicians Association
Minneapolis Fire Department Relief 165,395 15,777 11,714
Association
Minneapolis Police Relief Association 264,282 41,230 967
Minnesota School Boards Association 67,554 42,090 42,056
Insurance Trust
Mohawk Valley Physician's Health Plan 66,183 178,909 175,637
Municipal Improvement Corporation/Los 69,061 151,037 158,579
Angeles
Mutual of America Life Insurance Company 5,521,94 746,637 718,746
0
National Rifle Association of America 111,019 101,781 139,022
New Albany-Floyd County School Building 57,932 1,242 51
Corporation
Physicians Health Plan, Inc. 56,639 178,754 178,352
Regional Airports Improvement 489,656 38,936 38,936
Corporation
Sisters of Providence Good Health Plan 58,863 117,663 111,068
of Oregon
The Buffalo Enterprise Development 78,897 2,192 2,926
Corporation
Trans-Alaska Pipeline Liability Fund 327,579 37,746 57,633
Tufts Associated Health Maintenance 88,902 311,821 300,897
Organization
Washington Dental Service 73,670 191,874 188,824
Labor and agricultural organizations
----------------------------------------------------------------------
AFL-CIO 77,991 69,037 61,736
Air Line Pilots Association 97,057 82,143 69,723
Amalgamated Clothing and Textile Workers 25,273 3,589 2,053
Union-Rochester Joint Board
American Federation of State, County and 26,862 77,326 74,497
Municipal Employees
American Federation of Teachers, AFL- 51,073 69,280 63,279
CIO
Atlantic Coast District ILA 26,130 3,275 2,726
Bakery Confectionery and Tobacco Workers 24,178 11,875 12,056
International
Carrier-ILA Container Freight Station 33,375 14,544 2,330
Trust Fund
Dakota's Areawide IBEW-NECA Pension Fund 35,770 3,447 1,295
Directors Guild of America 45,632 10,553 7,029
District Council 37 Benefits Fund Trust 147,285 155,707 138,853
Educational and Cultural Trust Fund of 30,534 1,766 6,926
the Electrical Industry
Holstein-Friesian Association of America 27,845 16,166 16,866
International Brotherhood of Electrical 23,421 5,612 4,342
Workers #5
International Brotherhood of Painters 36,924 24,445 23,483
and Allied Trades
International Brotherhood of Teamsters 138,104 98,321 129,850
International Ladies Garment Workers 61,032 43,539 45,896
International Ladies Garment Workers 383,316 83,969 66,865
Union
International Longshoremens 39,479 10,635 10,684
International Union of Electronic 51,441 21,792 19,982
Workers, AFL-CIO
International Union of Operating 85,802 36,854 23,522
Engineers
International Union, UAW 1,052,77 386,988 365,476
5
Joint Employment Committee 23,606 1,923 1,009
Laborers International Union of North 151,957 52,223 82,546
America
Local 32B-32J Service Employees 64,207 24,406 17,201
International Union
Local One, Amalgamated Lithographers of 30,112 3,806 17,748
America
Los Angeles County Fair Association 88,041 30,297 29,446
Major League Baseball Players 128,461 38,974 5,927
Association
Michigan Education Association 23,529 41,881 43,198
National Education Association of US, 127,661 186,472 186,754
Inc.
National League of Postmasters 26,533 33,892 91,700
New York City District Council 37, 31,216 26,166 24,654
AFSCME, AFL-CIO
North Carolina Farm Bureau Federation, 22,491 6,425 4,321
Inc.
Retail Wholesale and Department Store 40,690 6,779 2,380
Union, Local 338
Retail Wholesale And Department Store 24,108 8,165 9,497
Union
Screen Actors Guild, Inc. 40,832 25,747 28,798
Seafarers Harry Lundeberg School of 40,183 9,371 15,426
Seamanship
Service Employees International Union 45,325 57,935 55,026
UAW-Chrysler Skill Development And 55,368 50,248 28,835
Training Program
United Brotherhood of Carpenters and 154,532 58,204 56,542
Joiners of America
United Food And Commercial Workers 127,861 117,159 108,752
International Union
United Mine Workers of America 127,765 37,887 26,077
United Paperworkers International Union 33,025 28,114 26,415
United States Letter Carriers Mutual 67,931 20,145 17,557
Benefit Association
United Steelworkers of America 194,904 232,187 237,493
International Union
United Transportation Union 48,407 40,937 37,326
Business leagues
----------------------------------------------------------------------
Academy of Motion Picture Arts and 38,730 17,431 11,909
Sciences
AIPSO 19,552 11,339 34,291
Air Transport Association of America 13,234 35,871 35,871
Alabama Insurance Guaranty Association 23,383 11,357 11,164
American Association of Nurse 10,786 8,906 7,496
Anesthetists
American Association of Oral And 12,979 7,373 6,881
Maxillofacial Surgeons
American Bankers Association 82,702 53,318 50,732
American Bar Association 117,925 95,142 88,439
American Board of Family Practice 11,713 5,993 5,334
American Board of Obstetrics and 9,600 3,508 3,046
Gynecology, Inc.
American Board of Psychiatry and 10,187 5,708 4,055
Neurology
American College of Emergency Physicians 10,135 13,580 13,506
American Dental Association 52,635 43,240 46,023
American Gas Association 24,817 59,383 59,148
American Hardware Manufacturing 17,846 7,771 6,451
Association
American Health Care Association 10,707 10,709 10,373
American Health Information Management 17,447 8,243 9,304
Association
American Hospital Association 83,379 85,474 85,088
American Institute of Architects 44,446 31,396 34,988
American Institute of Certified Public 71,502 120,200 117,745
Accountants
American Insurance Association Inc. 10,785 22,607 23,595
American Medical Association 215,144 170,186 174,571
American Nurses Association 11,798 21,375 19,132
American Petroleum Institute 40,790 69,510 70,728
American Pharmaceutical Association 9,291 9,956 9,954
American Physical Therapy Association 16,447 17,017 16,484
American Plywood Association 9,315 13,757 13,464
American Public Transit Association 14,225 9,325 9,142
American Society of Association 12,013 15,752 15,595
Executives
American Society of Hospital Pharmacists 29,375 24,837 23,021
American Speech-Language-Hearing 26,872 16,330 16,088
Association
American Trucking Association, Inc. 21,192 27,482 27,018
American Veterinary Medical Association 15,263 13,122 12,885
Americus-Sumpter Payroll Development 9,644 1,993 771
Authority
AMT -The Association for Manufacturing 19,372 17,879 17,065
Technology
Arkansas Capital Corporation 16,976 1,303 1,079
Association for Information And Image 14,571 9,992 7,873
Management
Association of American Railroads 41,007 93,240 83,106
ATP Tour, Inc. 24,922 42,759 42,350
Attorney Registration and Disciplinary 13,495 7,216 5,842
Commission of the Supreme Court of
Illinois
Audio Digest Foundation 17,997 8,201 7,753
Bank Administration Institute 14,620 4,358 4,385
Baseball Office of the Commissioner 18,651 15,636 14,636
Breeders' Cup Limited 31,510 30,041 24,973
Cable Television Labs, Inc. 19,305 11,176 10,046
California Association of Hospitals and 16,939 12,353 12,572
Health Systems
California Association of Realtors 12,541 15,961 15,808
California Dental Association 70,445 16,881 10,617
California League of Savings 12,974 2,650 2,776
Institutions
California Medical Association, Inc. 10,319 16,154 16,891
Career College Association 6,812 10,337 10,792
Central Minnesota Development Company 13,290 1,110 1,087
Chamber of Commerce of the USA 40,916 67,474 80,186
Chemical Industry Institute of 20,924 15,454 15,489
Toxicology
Chemical Specialties Manufacturers 9,383 3,811 3,519
Association
Chicago Bar Association 16,590 7,526 7,246
Connecticut Insurance Guaranty 55,187 10,636 23,394
Association
Construction Industry Manufacturing 15,519 8,513 3,425
Association
Cosmetic Toiletry And Fragrance 12,611 8,498 8,396
Association
Credit Union National Association, Inc. 12,837 24,028 22,875
Delaware Insurance Guaranty Association 13,921 8,348 3,063
Edison Electric Institute 46,546 61,299 59,154
Electronic Industries Association 47,914 41,440 34,668
Empire State Electric Energy 32,443 2,500 2,625
Florida Insurance Guaranty Association, 45,203 147,783 221,720
Inc.
Florida Self Insurers Guaranty Unknown 6,552 7,397
Association, Inc.
Food Marketing Institute 34,241 34,347 33,354
Georgia Insurers Insolvency Pool 18,308 1,511 5,743
Greater Erie Industrial Development 14,271 1,079 365
Corporation
Greater Seattle Chamber of Commerce 10,117 7,746 7,764
Health Insurance Association of America 17,963 27,355 32,675
Illinois Hospital Association 16,859 10,769 10,077
Illinois Insurance Exchange Guaranty 18,459 1,686 2
Fund, Inc.
Illinois Insurance Guaranty Fund 47,792 23,896 18,887
Independent Bankers Association of 11,376 8,652 8,024
America
Independent Insurance Agents of America 14,324 11,105 9,289
Indiana Life and Health Insurance 43,640 33,291 36,670
Guaranty Association
Institute of Electrical And Electronics 109,639 110,474 107,237
Engineers
International Council of Shopping 17,639 18,789 17,285
Centers, Inc.
Investment Company Institute 14,518 23,255 22,372
Louisiana Insurance Guaranty Association 28,805 70,760 75,814
Maine Insurance Guaranty Association 15,126 14,039 14,650
Marine Preservation Association 25,660 104,117 85,902
Massachusetts Insurers Insolvency Fund 56,289 33,155 23,782
Massachusetts Medical Society 60,218 55,584 53,005
Medical and Chirurgical Faculty of 15,198 4,387 3,791
Maryland
Medical Society of the State of New York 11,369 8,102 8,533
Michigan Automobile Insurance Placement 312,544 242,643 239,053
Facility
Michigan Basic Property Insurance 52,602 94,813 76,990
Association
Michigan Credit Union League 17,564 5,557 5,180
Michigan Life And Health Insurance 9,289 9,474 7,728
Guaranty Association
Michigan Property And Casualty Guaranty 30,056 9,560 15,067
Association
Million Dollar Round Table of the 13,528 8,473 7,755
National Association of Life
Underwriters
Minnesota Insurance Guaranty Association 40,073 24,099 25,490
Minnesota Life and Health Insurance 25,524 5,053 14,094
Guaranty Association
Minnesota Workers Compensation Insurers 46,595 7,138 3,337
Association, Inc.
Mississippi Insurance Guaranty 15,020 5,172 3,945
Association
Mississippi Life And Health Insurance 13,736 3,349 3,341
Guaranty Association
Missouri Joint Underwriting Association 11,197 7,779 8,808
Motion Picture Association of America 20,393 29,322 27,860
Motor Vehicle Accident Indemnification 54,770 34,706 33,023
Corporation
NASDAQ, Inc. 79,045 62,313 46,554
National Academy of Recording Arts and 19,745 15,769 11,734
Sciences, Inc.
National Association of Chain Drug 12,636 14,460 13,549
Stores
National Association of Convenience 9,596 7,818 6,961
Stores
National Association of Music Merchants, 15,057 5,889 4,733
Inc.
National Association of Printers And 17,254 3,305 3,253
Lithographers
National Association of Professional 24,617 5,512 5,397
Insurance Agents
National Association of Realtors 51,529 48,611 57,469
National Association of Securities 286,251 161,972 144,034
Dealers, Inc.
National Automobile Dealers Association 42,173 23,468 18,774
National Cargo Bureau 9,874 8,971 7,989
National Council on Compensation 48,693 100,215 98,890
Insurance
National Electrical Manufacturers 9,282 11,760 11,495
Association
National Federation of Independent 30,553 63,160 61,917
Business, Inc.
National Food Processors Association 29,228 17,481 16,557
National Hot Rod Association 23,375 44,120 41,377
National Institute for Automotive 11,500 10,933 8,300
Service Excellence
National Live Stock and Meat Board 13,623 53,977 52,773
National Rural Electric Cooperative 39,192 54,625 53,857
National Soft Drink Association 12,230 10,298 7,033
National Solid Wastes Management 11,110 14,938 14,001
Association
National Telephone Cooperative 14,940 7,600 7,075
Association
National Wholesale Druggists' 11,212 7,372 6,870
Association
New Hampshire Automobile Reinsurance 79,042 32,113 1,924
Facility
New Hampshire Insurance Guaranty 14,087 8,292 4,796
Association
New Jersey Hospital Association 43,160 7,329 6,889
New Jersey Property Liability Insurance 34,462 174,652 8,618
Guaranty Association
New Jersey Surplus Lines Insurance 34,816 26,043 1,579
Guaranty Fund
New Mexico Property and Casualty 9,548 10,343 6,902
Insurance Guaranty Association
New York Shipping Association, Inc. 51,823 181,265 83,085
New York State Bar Association 11,784 13,167 12,287
Newspaper Association of America 26,263 32,225 32,786
North Carolina Insurance Guaranty 17,056 9,042 10,145
Association
North Carolina Life and Health Guaranty 33,999 48,129 23,419
Association
North Dakota Insurance Guaranty 1,724 137 212
Association
Northern California Golf Association 11,087 3,478 2,992
Ohio Education Association 11,429 28,297 28,291
Ohio Insurance Guarantee Association 57,319 13,211 10,398
Ohio Life And Health Insurance Guaranty 92,509 43,250 8,993
Association
Ohio State Bar Association 11,762 5,734 5,065
Oklahoma Property and Casualty Insurance 20,665 10,627 5,615
Guaranty Association
Open Software Foundation 27,876 61,860 61,860
Packaging Machinery Manufacturers 11,710 9,051 8,100
Institute
Pennsylvania Chamber of Business and 9,639 3,508 3,087
Industry
Pennsylvania Insurance Guaranty 128,763 11,282 14,103
Association
Pennsylvania Life and Health Insurance 45,503 69,883 71,326
Guaranty Association
Pennsylvania Medical Society 23,816 8,634 8,453
Pennsylvania Professional Liability 58,275 8,852 3,727
Joint Underwriters
Pennsylvania State Education Association 22,988 30,829 31,033
PGA Tour, Inc. 199,157 174,111 171,341
Portland Cement Association 13,745 10,486 13,439
Printing Industries of America, Inc. 9,711 8,954 9,576
Public Securities Association 11,124 13,310 12,297
Realtors National Marketing Institute of 9,958 7,043 7,546
the National Association of Realtors
Regional IDC of Southwestern 111,673 18,241 19,231
Pennsylvania
Retail Merchants Association of Greater 26,024 2,233 2,287
Richmond
Rhode Island Automobile Insurance Plan 15,638 3,768 3,372
Rhode Island Insurers Insolvency Fund 14,785 19,882 14,680
Savings And Community Bankers of America 28,290 22,394 24,377
Savings Banks Life Insurance Fund 17,592 10,858 10,367
Securities Investor Protection 734,867 73,450 16,850
Corporation
Self Insurers Security Fund 21,465 6,589 5,078
Semiconductor Equipment and Materials 15,222 17,349 16,457
International
Semiconductor Research Corporation 10,491 35,028 35,620
Sheet Metal and Air Conditioning 9,492 5,437 6,048
Contractors' National Association
Snake River Power, Inc. 14,485 1,333 1,330
Society for Human Resource Management 14,404 15,433 14,848
South Carolina Property and Casualty 9,705 4,001 3,264
Insurance Guaranty Association
State Medical Society of Wisconsin 10,288 4,633 4,542
Tennessee Insurance Guaranty Association 13,354 1,845 1,620
Texas Life Accident Health and Hospital 63,062 75,747 27,989
Service Insurance Guaranty Association
Texas Medical Association 28,721 12,601 12,286
Texas Property And Casualty Insurance 91,068 120,515 97,641
Guaranty Association
Textile Hall Corporation 21,350 4,539 2,042
The American Society of 21,889 13,922 11,318
Anesthesiologists
The Association of Trial Lawyers of 13,235 15,144 16,531
America
The Council for Tobacco Research-USA, 15,111 25,666 25,491
Inc.
The Economic Development Partnership of 28,497 14,829 3,599
Alabama
The Hospital Association of Pennsylvania 194,846 7,200 7,695
The Medical Society of the District of 9,990 2,153 2,033
Columbia
The National Association of Life 13,135 18,466 22,341
Underwriters
The Professional Golfers' Association of 44,090 32,647 29,902
America
The Society of the Plastics Industry, 28,419 77,212 76,310
Inc.
Uniform Code Council, Inc. 49,007 10,372 4,636
United States Tennis Association, Inc. 74,862 82,235 90,747
University Research Park, Inc. 14,953 1,815 1,281
Virginia Property And Casualty Insurance 13,579 2,109 6,997
Guaranty Association
WACO Industrial Foundation 12,149 209 275
Wisconsin Insurance Security Fund 13,870 14,602 11,062
Wisconsin Workers Compensation Insurance 224,116 125,086 103,487
Pool
York County Industrial Development 226,400 483 446
Authority
York County Industrial Development 15,728 1,045 996
Corporation
----------------------------------------------------------------------
Source: GAO analysis of IRS data.
CATEGORY AND TYPE OF TAX-EXEMPT
ORGANIZATIONS UNDER IRC SECTION
501(C)
========================================================== Appendix IV
Section 501 (c)
category Types of tax-exempt organizations
------------------ --------------------------------------------------
(1) Corporations organized under an act of Congress
and operated as an instrumentality of the United
States, for example, Federal Deposit Insurance
Corporation.
(2) Title holding corporations organized to hold title
to property of a tax-exempt organization, collect
the income, and deliver the net proceeds to the
exempt organization.
(3) Entities organized and operated exclusively for
religious and charitable, scientific, testing for
public safety, literacy, or educational purposes,
or for the prevention of cruelty to children or
animals, or to foster amateur sports.
(4) Civic leagues or organizations operated
exclusively for the promotion of social welfare or
local associations of employees (earnings devoted
to charitable, educational, or recreational
purposes).
(5) Labor, agricultural, and horticultural
organizations organized to provide education and
instruction on improving working conditions and
products.
(6) Business leagues, chambers of commerce, real
estate boards, and professional football leagues
organized to improve business conditions.
(7) Clubs organized for pleasure and recreational
purposes.
(8) Fraternal beneficiary societies and associations
organized to provide for the payment of life,
sickness, accident or other benefits to members
and operated under a framework of self-governing
branches chartered by a parent organization.
(9) Voluntary employee beneficiary association
providing for payment of life, sickness, accident
or other benefits to members of the association.
(10) Domestic fraternal societies and associations
operated exclusively for social, educational,
religious, scientific, charitable, and fraternal
purposes under a framework of self-governing
branches chartered by a parent organization.
(11) Teachers' retirement fund associations organized
on a local basis.
(12) Benevolent life insurance associations; mutual
companies, such as electric, irrigation, and
cooperative companies organized on a local basis.
(13) Cemetery companies owned and operated for the
benefit of their members and not operated for
profit.
(14) Nonprofit credit unions and mutual reserve funds
providing loans to members and reserve funds for
domestic building and loan associations,
cooperative banks and mutual savings banks,
(mutuals must have been organized before 9/1/57).
(15) Mutual insurance companies or associations, with
net premiums not more than $350,000 providing
insurance to members (other than life companies).
(16) Cooperative organizations established to finance
crop operations.
(17) A trust or trusts providing for the payment of
supplemental unemployment benefits.
(18) A trust providing for the payment of benefits
under a pension plan funded by employees, created
prior to 6/25/59.
(19) A post or organization promoting the welfare of
past or present members of the Armed Forces.
(20) An organization or trust providing legal services
as part of a qualified group legal services plan.
(21) A trust or trusts organized to meet black lung
disability and liability claims.
(22) Pension plan withdrawal liability trust created to
provide funds to meet payments under section
4223(c) or (h) of the Employee Retirement Income
Security Act of 1974.
(23) Veterans' insurance associations created to
provide insurance and other benefits to member
veterans.
(24) Trusts described in section 4049 of the Employee
Retirement Income Security Act of 1974.
(25) Title-holding companies with 35 or fewer entities
exempt under IRC section 401 and 501(c)(3) and
governmental units.
----------------------------------------------------------------------
Source: IRC.
MAJOR CONTRIBUTORS TO THIS
BRIEFING REPORT
=========================================================== Appendix V
GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C.
Michael Brostek, Assistant Director
Mary Phillips, Assignment Manager
Robert McKay, Evaluator-in-Charge
Bryon Gordon, Evaluator
Pat McGuire, Senior Computer Specialist
Susan Baker, Computer Specialist
Katherine M. Wheeler, Publishing Advisor
Hazel Bailey, Writer-Editor
Rosa Hayes, Secretary
*** End of document. ***