Laborers' International Union of North America - Page 4

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          sponsor, or provide the insurance program operated by the Mail              
          Handlers’ health plan.3                                                     
               Petitioner raises funds to cover its cost of operation by              
          levy of a “per capita tax” on its own members and on affiliated             
          unions.  Per capita taxes are the traditional way that national             
          and international unions fund their activities to accomplish                
          their exempt purposes.  During the subject years, petitioner                
          levied a per capita tax on Mail Handlers.  The tax was calculated           
          with reference to the number of regular and associate members of            
          Mail Handlers.  These per capita taxes were set at different                
          rates for the associate and regular members.  During the years in           
          issue, petitioner engaged in the following activities: Serving as           
          the voice of its regular members in the labor movement at large             
          and operating a substantial legislative department that lobbies             
          Congress and Federal agencies for legislation and regulations               
          that will benefit its regular members and affiliated bodies.                
          Petitioner also engaged in coordinating the legal strategy and              
          efforts for its affiliates and providing direct legal services              
          where appropriate, maintaining professionally staffed departments           
          for research, education, international affairs public relations,            
          membership, jurisdiction, organizing, construction, maintenance,            
          and service trades, and others that work for the direct benefit             

               3 Respondent concedes that the activities of Mail Handlers             
          are not attributable to petitioner.                                         

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Last modified: May 25, 2011