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Text of IRS Private Letter Ruling 201322051: Plan for Employees of College Preparatory School Is Entitled to Church Plan Exemption (PDF)
Internal Revenue Service [IRS]
[Official Guidance] June 2, 2013
"The governing body of School S is a Board of Trustees ... of which no less than one-third plus one shall be members of Society J, which is a religious order of men.... [T]he Board of Trustees has the authority to elect the President of School S by a two-thirds majority of the Board of Trustees and by a majority of the members of Society J then on the Board of Trustees ... School S is listed in Directory C and, consequently, is exempt from federal income taxes under Section 501 ... In view of the common religious bonds between School S and Society J, the inclusion of School S in Directory C, and the indirect control of School S by Society J through the Board of Trustees, we conclude that School S is associated with a church ... within the meaning of Section 414(e)(3)D of the Code[.]"
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