TAILIEUCHUNG - M. STATE CHARTERED CREDIT UNIONS UNDER 501(c)(14)(A)

The funds in these portfolios must either be invested in high quality liquid securities (reported as held for trading or available for sale) or placed as deposits in central the Basel III proposal regarding the Net Stable Funding Ratio (NSFR) requirement is implemented, the liquidity portfolio required will increase even further. If the assets held in banks’ liquidity portfolios and reported as held for trading or available for sale are included in the threshold calculations, this will give banks aiming at avoiding ring-fencing a strong incentive to place its funds as deposits at central. | 1979 EO CPE Text M. STATE CHARTERED CREDIT UNIONS UNDER 501 c 14 A Introduction State chartered credit unions without capital stock organized and operated for mutual purposes and without profit are exempt from Federal income tax under IRC 501 c 14 A . Federal credit unions are considered to be instrumentalities of the United States exempt from Federal income tax under the provisions of the Federal Credit Union Act 12 . S1768 thus qualifying for exemption under IRC 501 c 1 . The credit union area has been the subject of recent activity despite the small amount of published precedent in this area. This discussion is designed to provide the reader with background material in this area. 1. Legislative History Specific statutory language granting exemption for credit unions first appeared in the Code in 1951. Prior to that time credit unions generally qualified for tax exempt status under revenue statutes exempting building and loan associations and cooperative banks. However in 1951 Congress deleted from the Code the language according tax exempt status to mutual savings banks and federal and state savings and loan associations. While the legislative history of the Revenue Act of 1951 contains an extensive discussion concerning the reasons for the elimination of exempt status for mutual savings banks and domestic savings and loan associations it is silent with respect to the purpose for the continuation of exempt status for credit unions. However the probable reason for the continued favorable tax treatment of credit unions is contained in the reasons underlying the removal of exempt status for mutual savings banks and savings and loan associations. In reference to mutual savings banks the legislative history of the Revenue Act of 1951 states Mutual savings banks were established to encourage thrift and to provide safe and convenient facilities to care for savings. They also have the responsibility of investing the funds left with them so as to be able to give .

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