The IRS has been examining the reasons organizations have certain classes of members, what role these members play in running the organization and what benefits they receive as part of their membership. In the past, all membership dues were considered tax-exempt income. In both situations, it was stated that the associate members were not bona fide members of the organization, and that these members joined solely to receive benefits unrelated to the exempt purpose of the organizations. In applying this revenue procedure, the IRS looks to the purpose and activities of the organization rather than those of its members. Associate members do not gain full participation in the association, and do not receive a right to participate in its organizational direction.
Associate members lack significant, meaningful participation in the organization's exempt functions.
The association can successfully accomplish its exempt purpose with just its regular members. Associate member dues are closely tied to unrelated benefits received. Associate members pay higher dues than do regular members, yet receive fewer benefits.