Subject: Tax Exempt Status

Governing Board Approval: June 11, 1993

DISTRICT OF COLUMBIA / UNITED STATES OF AMERICA

Based on information furnished to it by the Council, the Internal Revenue Service of the United States of America has determined that IBAC is an organization exempt from Federal income tax under the provisions of Section 501(c)(6) of the Internal Revenue Code. The determination is predicated on IBAC's continued adherence to operations as stated in its application for exemption.

The organization is liable for payment of certain excise, employment and other Federal taxes applicable to the employment of persons for wages or periods in excess of stated minima during calendar years. IBAC has been assigned IRS Employer Identification Number 52-1220321.

IBAC is also responsible for filing certain IRS Forms (notably Form 990) based on the amount of its gross annual receipts.

The District of Columbia, U.S.A., has also determined that the Council is exempt from District income and franchise tax but must file reports on certain financial data annually.

Determination letters from IRS and the District government are on file in the IBAC Corporate Secretary's records.

Source of Policy: (1) Internal Revenue Service, District Director (Baltimore) letter of January 11, 1982.

(2) Government of the District of Columbia, Department of Finance and Revenue Letter of December 29, 1981.

PROVINCE OF QUEBEC/CANADA

The Government of the Province of Quebec has granted certain privileges to IBAC. These are enshrined in an Accord between the Government of Quebec and IBAC which was consummated August 7, 1991.

The Accord, based on the fact that IBAC is an International Non-Governmental Organization (INGO), grants certain tax exemptions for IBAC. IBAC is exempt from provincial corporate income taxes, but it must however file an annual nil tax return. IBAC is eligible for a refund of certain provincial sales tax. IBAC is not required to adhere to the laws regulating the use of the French language. IBAC must contribute to certain specified government schemes on behalf of employees.

IBAC is exempt from federal corporate income taxes, but it must however file an annual nil tax return. IBAC is eligible for a refund of the Federal Goods and Service Tax (GST).

Further information is available in the IBAC administrative files.