Tax Type
Retail Sales and Use Tax
Description
Camp for special needs children
Topic
Exemptions
Date Issued
11-07-1989
November 7, 1989
Re: Request for Ruling/Sales and Use Tax
Dear**************
This is in reply to your letter of September 7, 1989, in which you request a ruling whether your organization qualifies for exemption from the sales and use tax.
FACTS
************* (the Taxpayer), is a nonprofit organization exempt from income taxation under §501(c)(3) of the Internal Revenue Code, which provides a normal camp environment for children with special needs or disabilities. You seek an exemption to allow the Taxpayer to purchase items exempt from the Virginia retail sales and use tax.
RULING
Virginia Code §58.1-608(7)(h) provides a sales and use tax exemption for the following:
Tangible personal property purchased by a voluntary health organization exempt from taxation under §501(c)(3) of the Internal Revenue Code and organized exclusively for the purpose of providing direct therapeutic and rehabilitative services, such as speech therapy, physical therapy, and camping and recreational activities, to the children and adults of the Commonwealth regardless of the nature of their disease or socioeconomic position. Emphasis added.
Based on the purpose of your organization as outlined in the documentation you have provided, I find that your organization qualifies for the exemption cited above. Please note that this exemption applies only to tangible personal property purchased for use and consumption by the Taxpayer.
I If you have any further questions, please feel free to contact the department.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner