UC Fee Exempt

0058-EX-RR-2010 Text Documents

Regents of the University of California

2010-03-02ELS_104993

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      District                                     450 Golden Gate Ave.
      Director                                     San Francisceo, Calit 94102

                                                   Person to Contact:
     * The Regents of the University               Desk Officer
         of California                             Telephone Number:
      c/o The Office of the Ceneral                (415) 556—53%53
        Counsel                                    Refer Reply to:
      590 University Hall                            EP/EO:l
      2200 University Avenue                      .. Date:
      Berkeley, CA 94 72‘0                       . 8 SCP   r~ 1982


      Re:    Request for Confirmation of Exempt
             Status under Section 5Ql(c)(3) of
             the Internal Revenue Code of 1954


      Dear Regents:

      This is in reference to your letter of July 13, 1982 requesting confirmation
      of the exempt status of The Regents of the University of California under
      section 501(c)(3) of the Internal Revenue Code of 1954.

      In our letter of September 14, 1939, Code IT:P:T:Ll CQ, it was held that
      you were entitled to exemption under the provisions of section 101(6) of
      the Revenue Act of 1938.

      A determination or ruling letter issued to an organization granting
      exemption under the Internal Revenue Code of 1954 or under a prior or
      subsequenat Revenue Act remains in effect until exempt status has been
     _terminated, revoked or modified.

      Our records indicate that you are the regularly constituted state university
      of the State of California originally created by a state legislature act of
      1868 ; that you are engaged in educational activities; that your income is
      derived from investments, endowments, tuition, and miscellaneous sources;
      anad that your income is used in furtherance of your educational activities.

      In addition, it appears from our records (fiacludxng the. information submitted
      with your lecter of July 13, 1982), that there has been no. change in your
      organization‘s exempt status. Accordingly, our letter of September 14, 1939
      is still in effect. This letter does not constitute a no change examination                       sz
      letter .
                                                                                                   o
      Because section SO0li(c)(3) of the Enternal Revenue Code of 1994 was derived
      from and continues, without substantive change, the language of section
      101(6) of the Revenue Act of 1938 ("1939 Code") and because our letter of
      September 14, 1939 is still in effect, it appears that you and your
      constituent units are entitled to exemption as an organization described
      in section SOl(c}(3) of the 1934 Code.

      Donors may deduct contributions to you as provided in section 170 of the
      Internal Revenue Code of 1954 (formerly section 23(0) of the Internal


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            The Regents of the Universiry of California
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            Revenue Code of 1938).   Bequests, legacies, devises, transfers, or gifts
            to you or for your use are deductible for Federal estate and gift tax
            purposes as provided in the applicable provisions of sections 2055, 2106,
            and 2522 of the Internal Revenue Code of 1954 .

           You are not required to file Form 990, Return of Organization Exempt from
            Income Tax, because you are a State institution, the income of which is
           excluded from gross income under section l15(a) of the Interual Revenue
           Code of 1954.                                          —

           You are not required to file Federal income tax returns unless you are
           subject to the tax on unrelated business income under section 511 of the
           Code. If you are subject to this tax, you must file an income tax return
           on Form 990—T. This office has not been asked to consider and therefore,
           in this letter, we are not determuining whether anmny of your present or
           proposed activities are unrelated trade or business as defined in section
           513 of the Internal Revenue Code of 1954.

           Because this letter could help resolve any questions about your exempt
           status, you should keep it in your permanent records.

           If you have any questions, please contact the person whose name and
           telephone are shown in the heading of this letter.

                                                     Sincerely,


                                                     Miche]) Sm
                                                    District Dxrec:or




                                                                                      TOTHL P.03



Document Created: 2019-04-08 17:14:15
Document Modified: 2019-04-08 17:14:15

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