Proposed Rule2026-18127
Racial Nondiscrimination in Private Schools
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
September 4, 2026
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
This document contains proposed regulations that would update existing regulations to provide that a private school is not described as an organization exempt from Federal income tax if it discriminates on the basis of race, color, or national or ethnic origin in administration of its educational, admissions, scholarship, athletic, or other policies, based on the fundamental public policy of the United States against such practices. These proposed regulations would affect private schools in taxable years beginning after May 31, 2027, which is after the final regulations are expected to be published.
Full Text
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<title>Federal Register, Volume 91 Issue 171 (Friday, September 4, 2026)</title>
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[Federal Register Volume 91, Number 171 (Friday, September 4, 2026)]
[Proposed Rules]
[Pages 56811-56819]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-18127]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-119986-25]
RIN 1545-BS05
Racial Nondiscrimination in Private Schools
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking.
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SUMMARY: This document contains proposed regulations that would update
existing regulations to provide that a private school is not described
as an organization exempt from Federal income tax if it discriminates
on the basis of race, color, or national or ethnic origin in
administration of its educational, admissions, scholarship, athletic,
or other policies, based on the fundamental public policy of the United
States against such practices. These proposed regulations would affect
private schools in taxable years beginning after May 31, 2027, which is
after the final regulations are expected to be published.
DATES: Written or electronic comments and requests for a public hearing
must be received by November 3, 2026.
ADDRESSES: Commenters are strongly encouraged to submit public comments
electronically via the Federal
[[Page 56812]]
eRulemaking Portal at <a href="https://www.regulations.gov">https://www.regulations.gov</a> (indicate IRS and
REG-119986-25) by following the online instructions for submitting
comments. In accordance with 5 U.S.C. 553(b)(4), a plain language
summary of these proposed regulations is also available on the Federal
eRulemaking Portal. Requests for a public hearing must be submitted as
prescribed in the ``Comments and Requests for a Public Hearing''
section. Once submitted to the Federal eRulemaking Portal, comments
cannot be edited or withdrawn. The Department of the Treasury (Treasury
Department) and the IRS will publish for public availability any
comments submitted to the IRS's public docket. Send paper submissions
to: CC:PA:01:PR (REG-119986-25), Room 5503, Internal Revenue Service,
P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning these proposed regulations,
the Office of Associate Chief Counsel (Employee Benefits, Exempt
Organizations, and Employment Taxes) at (202) 317-6000 (not a toll-free
number); concerning submission of comments or requests for a public
hearing, the Publications and Regulations Section at (202) 317-6901
(not a toll-free number) or by email at <a href="/cdn-cgi/l/email-protection#9eeeebfcf2f7fdf6fbffecf7f0f9eddef7ecedb0f9f1e8"><span class="__cf_email__" data-cfemail="027277606e6b616a6763706b6c6571426b70712c656d74">[email protected]</span></a>
(preferred).
SUPPLEMENTARY INFORMATION:
Authority
This notice of proposed rulemaking contains proposed amendments to
the Income Tax Regulations (26 CFR part 1) that would add a new Sec.
1.501(c)(3)-2 issued under section 501(c)(3) of the Internal Revenue
Code (Code).
These proposed regulations are issued pursuant to section 7805(a)
of the Code, which authorizes the Secretary of the Treasury or the
Secretary's delegate to ``prescribe all needful rules and regulations
for the enforcement of [the Code], including all rules and regulations
as may be necessary by reason of any alteration of law in relation to
internal revenue.''
Background
I. Statute and Applicable Regulations
Section 501(c)(3) describes, in part, organizations that are
organized and operated exclusively for ``charitable . . . or
educational purposes'' provided certain restrictions on private
inurement, lobbying, and intervention in political campaigns are not
violated. Such organizations are generally exempt from Federal income
tax by section 501(a). Section 170 of the Code provides, in part, a
deduction to taxpayers who make ``charitable contributions'' to
organizations specified in section 170(c)(2), which essentially mirrors
the description of organizations satisfying the requirements of section
501(c)(3). In determining the amount of a taxpayer's deduction allowed
under section 170(a) within the taxable year, section 170(b)(1)(A)(ii)
includes any charitable contribution to an educational organization
that normally maintains a regular faculty and curriculum and normally
has a regularly enrolled body of pupils or students in attendance at
the place where its educational activities are regularly carried on.
Section 1.170A-9(c)(1) provides that an ``educational organization'' is
described in section 170(b)(1)(A)(ii) if its primary function is the
presentation of formal instruction and it normally maintains a regular
faculty and curriculum and normally has a regularly enrolled body of
pupils or students in attendance at the place where its educational
activities are regularly carried on. The term includes institutions
such as primary, secondary, preparatory, or high schools, and colleges
and universities. It includes Federal, State, and other public-
supported schools that otherwise come within the definition.
Sections 170(c)(2), 170(b)(1)(A)(ii), and 501(c)(3) do not further
define the terms ``charitable'' or ``educational'' or explain what it
means to be organized and operated exclusively for such purposes.
For over 65 years, however, the provisions of Sec. 1.501(c)(3)-1
have provided guidance on the interpretation of the terms
``charitable'' and ``educational'' as used in section 501(c)(3).
Section 1.501(c)(3)-1(a) provides that, in order to be exempt under
section 501(a) as an organization described in section 501(c)(3), the
organization must be both organized and operated exclusively for one or
more of the purposes specified in section 501(c)(3), as defined and
elaborated in Sec. 1.501(c)(3)-1(d). Thus, an organization that fails
to meet either the ``organizational test'' set forth in Sec.
1.501(c)(3)-1(b) or the ``operational test'' set forth in Sec.
1.501(c)(3)-1(c) is not exempt from Federal income tax.
Section 1.501(c)(3)-1(d)(1) provides a list of purposes that would
allow an organization to be exempt as an organization described in
section 501(c)(3) if it is organized and operated exclusively for one
or more of the exempt purposes specified in section 501(c)(3), which
list includes charitable and educational purposes. Section 1.501(c)(3)-
1(d)(2) provides that the term ``charitable'' is used in section
501(c)(3) in its generally accepted legal sense and is, therefore, not
to be construed as limited by the separate enumeration in section
501(c)(3) of other tax-exempt purposes that may fall within the broad
outlines of ``charity'' as developed by judicial decisions. In
addition, Sec. 1.501(c)(3)-1(d)(2)(ii) states that the term includes
the ``promotion of social welfare by organizations designed to . . .
eliminate prejudice and discrimination.''
Similar to the description of an educational organization in
section 170(b)(1)(A)(ii), Sec. 1.501(c)(3)-1(d)(3)(ii), (Example 1),
provides that a primary or secondary school, a college, or a
professional or trade school, that has a regularly scheduled
curriculum, a regular faculty, and a regularly enrolled body of
students in attendance at a place where the educational activities are
regularly carried on may qualify for exemption as an educational
organization of the character contemplated by section 501(c)(3) if it
otherwise meets the requirements of section 501(c)(3).
II. Policy of the United States Against Racial Discrimination in
Education
On May 17, 1954, the Supreme Court of the United States decided
Brown v. Board of Education of Topeka, Kansas, 347 U.S. 483 (1954), in
which the Court held that state-sanctioned racial segregation of public
schools violates the Equal Protection Clause of the Fourteenth
Amendment. One year later, the Court reiterated that ``full
compliance'' with Brown required public schools to admit the students
that had sued ``on a racially nondiscriminatory basis.'' Brown v. Board
of Education, 349 U.S. 294, 300-301 (1955).
Enacted into law on July 2, 1964, Title VI of the Civil Rights Act
of 1964 states, in relevant part, ``No person in the United States
shall, on the ground of race, color, or national origin, be excluded
from participation in, be denied the benefits of, or be subjected to
discrimination under any program or activity receiving Federal
financial assistance.''
In 1976, the Supreme Court decided the case of Runyon v. McCrary,
427 U.S. 160, holding that 42 U.S.C. 1981 (Section 1981) \1\ bars a
private school from discriminating against applicants
[[Page 56813]]
based on their race. The same year, the Supreme Court confirmed that
the protections of Section 1981 apply equally to all persons regardless
of race. McDonald v. Santa Fe Trail Transp. Co., 427 U.S. 273, 295
(1976).
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\1\ Section 1 of the Civil Rights Act of 1866 is codified at 42
U.S.C. 1981 and provides that all persons in the United States shall
have the same right to ``make and enforce contracts, to sue, be
parties, give evidence, and to the full and equal benefit of all
laws and proceedings for the security of persons and property as is
enjoyed by white citizens.''
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On June 30, 1971, the United States District Court for the District
of Columbia entered an order permanently enjoining the Treasury
Department and the IRS from recognizing as described in section
501(c)(3) any private school located in the State of Mississippi that
failed to adopt, publish, and operate under a racially
nondiscriminatory policy as to students and that failed to supply the
IRS with certain information to ensure operation on a nondiscriminatory
basis. Green v. Connally, 330 F. Supp. 1150 (D.D.C. 1971), aff'd sub
nom., Coit v. Green, 404 U.S. 997 (1971). The court stated that ``[t]he
Code must be construed and applied in consonance with the Federal
public policy against support for racial segregation of schools, public
or private.'' Id. at 1163. The court declared that section 501(c)(3)
``does not provide a tax exemption for ...any organization that is
operated for educational purposes unless the school or other
educational institution involved has a racially nondiscriminatory
policy as to students.'' Id. at 1179. It further declared that this
requires that ``the school or other educational institution admits the
students of any race to all the rights, privileges, programs and
activities generally accorded or made available to students at that
school, and which includes, specifically but not exclusively, a policy
of making no discrimination on the basis of race in administration of
educational policies, applications for admission, of scholarship and
loan programs, and athletic and extra-curricular programs.'' Id.
That year, the IRS issued Rev. Rul. 71-447, 1971-2 C.B. 230, which
states that a private school that does not have a racially
nondiscriminatory policy as to students does not qualify for exemption
from Federal income tax. Consistent with Green v. Connally, the revenue
ruling defines a ``racially nondiscriminatory policy as to students''
as meaning that the school admits the students of any race to all the
rights, privileges, programs, and activities generally accorded or made
available to students at that school and that the school does not
discriminate on the basis of race in administration of its educational
policies, admissions policies, scholarship and loan programs, and
athletic and other school-administered programs. In support, the
revenue ruling states, ``All charitable trusts, educational or
otherwise, are subject to the requirement that the purpose of the trust
may not be illegal or contrary to public policy,'' citing to common law
concepts of charity and the Restatement of Trusts.\2\ The revenue
ruling acknowledges that Federal statutory law does not prohibit the
operation of private schools on a discriminatory basis, but states that
the policy of the United States is to discourage discrimination in such
schools. The revenue ruling cites to the ``well-settled'' Federal
policy against discrimination in many areas of wide public interest and
to ``developments of recent decades and recent years reflect[ing] a
Federal policy against racial discrimination which extends to racial
discrimination in education. Titles IV and VI, The Civil Rights Act of
1964 . . . and Brown v. Board of Education . . . and many subsequent
Federal court cases, demonstrate a national policy to discourage racial
discrimination in education, whether public or private.''
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\2\ The Restatement of Trusts is a treatise published by the
American Law Institute that restates and clarifies the common law of
trusts in the United States.
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Based on the permanent injunction in Green v. Connally, the IRS
also issued Rev. Proc. 75-50, 1975-2 C.B. 587, modified by Rev. Proc.
2019-22, 2019-22 I.R.B. 1260, to set forth guidelines and recordkeeping
requirements for determining whether private schools that apply for
recognition of exemption from Federal income tax under section
501(c)(3), or are presently recognized as exempt from tax, have
racially nondiscriminatory policies as to students. Section 3.01 of
Rev. Proc. 75-50 defines a ``racially nondiscriminatory policy as to
students'' by reference to policies addressed by Rev. Rul. 71-447. The
first sentence of section 3.02 of Rev. Proc. 75-50 clarifies that
``discrimination on the basis of race'' includes discrimination on the
basis of color and national or ethnic origin. The second sentence of
section 3.02 of Rev. Proc. 75-50 states that a ``policy of a school
that favors racial minority groups with respect to admissions,
facilities and programs, and financial assistance will not constitute
discrimination on the basis of race when the purpose and effect is to
promote the establishment and maintenance of that school's racially
nondiscriminatory policy as to students.'' Likewise, the third and
fourth sentences of section 4.05 of Rev. Proc. 75-50 state:
``Consistent with section 3.02, supra, scholarships and loans that are
made pursuant to financial assistance programs favoring members of one
or more racial minority groups that are designed to promote a school's
racially nondiscriminatory policy will not adversely affect the
school's exempt status. Financial assistance programs favoring members
of one or more racial groups that do not significantly derogate from
the school's racially nondiscriminatory policy similarly will not
adversely affect the school's exempt status.''
On May 24, 1983, the Supreme Court decided Bob Jones University v.
United States, 461 U.S. 574 (1983). In that case, the Court held that
the IRS did not exceed its authority when it announced its
interpretation of section 501(c)(3) in Rev. Rul. 71-447, and upheld the
IRS's revocation of the section 501(c)(3) status of Bob Jones
University and the Goldsboro Christian Schools, Inc. These schools
maintained racially discriminatory policies promoting racial
segregation, which the Court held were contrary to a fundamental public
policy. Id. at 593. The Court reasoned that, in analyzing section
501(c)(3), there was unmistakable evidence that entitlement to a tax
exemption depends on meeting a ``charitable'' standard under common
law; that is, serving a public purpose and not being contrary to
established public policy. Id. at 586. The Court further stated, ``[a]n
unbroken line of cases following Brown v. Board of Education
establishes beyond doubt this Court's view that racial discrimination
in education violates a most fundamental national public policy, as
well as rights of individuals,'' specifying that ``[t]he right of a
student not to be segregated on racial grounds in schools . . . is
indeed so fundamental and pervasive that it is embraced in the concept
of due process of law.'' Id. at 593 (internal cites omitted). The court
also cited to numerous acts of Congress, including the Civil Rights Act
of 1964, and numerous executive orders ``demonstrating the commitment
of the Executive Branch to the fundamental policy of eliminating racial
discrimination'' for its conclusion that ``[r]acially discriminatory
educational institutions cannot be viewed as conferring a public
benefit within the `charitable' concept . . . or within Congressional
intent underlying Sec. 170 and Sec. 501(c)(3).'' Id. at 595-96.
The authorities described in this Background section establish that
racial discrimination in education violates a fundamental public policy
of the United States and that schools engaging in racial discrimination
are ineligible for section 501(c)(3) status.
[[Page 56814]]
III. Developments Regarding Racial Discrimination in Education
In the 1970s, some universities adopted ``affirmative action''
admissions policies considering race as one factor among others to
increase the enrollment of racial minority students in their programs,
and courts began to delineate constitutional limits, emphasizing that
programs must be narrowly tailored and serve compelling interests. For
example, the Supreme Court in Regents of the University of California
v. Bakke, 438 U.S. 265 (1978), addressed whether the University of
California violated the Fourteenth Amendment's Equal Protection Clause,
and Title VI of the Civil Rights Act of 1964, by practicing an
``affirmative action'' policy that resulted in the repeated rejection
of a white male's application for admission to its medical school.
The Bakke Court was divided. Led by Justice Stevens, four justices
concluded that Title VI categorically prohibited using race as the
basis for excluding persons from participation in federally funded
programs, and that the use of racial quotas in university admissions
constituted such an exclusion. 438 U.S. at 421. Four other justices,
led by Justice Brennan, argued that Title VI's prohibition on racial
discrimination was coextensive with the Equal Protection Clause of the
Fourteenth Amendment, that the Equal Protection Clause did not bar the
use of race-based criteria that were designed to mitigate the effects
of racial discrimination, and accordingly that the use of racial quotas
in admissions was not illegal. 438 U.S. at 328, 362, 378. Justice
Powell's opinion announcing the judgment of the Court landed between
these two camps. Powell concurred with Brennan that Title VI was
coextensive with the Equal Protection Clause, but found that any race-
based classification, even for a purportedly benign purpose, was
subject to strict scrutiny. Id. at 299. Justice Powell held that the
practice of setting a specific quota for specific racial groups could
not survive strict scrutiny, but that an admissions program which was
aimed at attaining the benefits of a diverse student body and treated
race as just one element among many in an applicant's profile was
constitutionally permissible. Id. at 318-20. Thus, although the Court
struck down the use of racial quotas, the Court allowed race to be
considered as one of many factors to be considered in admissions.
Approximately 25 years later, the Supreme Court addressed in
Grutter v. Bollinger, 539 U.S. 306 (2003), whether the University of
Michigan Law School's use of racial preferences in student admissions
violated the Equal Protection Clause of the Fourteenth Amendment or
Title VI of the Civil Rights Act of 1964. Looking to Justice Powell's
opinion in Bakke, the Court reiterated that maintaining the diversity
of a university's student body was a compelling state interest which
could justify race-conscious admissions policies. Id. at 325. The Court
further found that the University of Michigan's policies were narrowly
tailored to that interest because review of every student's application
was highly individualized, race was one of many types of diversity
considered in the process, and acceptance or rejection was not
automatic based on the presence of a single variable such as race. Id.
at 336-38. However, the Court noted that race-conscious admissions
policies should be limited in time since ``[a] core purpose of the
Fourteenth Amendment was to do away with all governmentally imposed
discrimination based on race.'' Id. at 341. The Court further stated
that ``racial classifications, however compelling their goals, are
potentially so dangerous that they may be employed no more broadly than
the interest demands,'' so a permanent justification for racial
preferences would be contrary to the principle of equal protection. Id.
at 342. Justice O'Connor expressed an expectation that 25 years from
the date of the opinion, ``the use of racial preferences will no longer
be necessary to further the interest approved today.'' 539 U.S. at 343
(internal citations omitted).
That same year, the Supreme Court, in Gratz v. Bollinger, 539 U.S.
244 (2003), addressed whether the University of Michigan's use of
racial preferences in undergraduate admissions violated the Equal
Protection Clause of the Fourteenth Amendment and Title VI of the Civil
Rights Act of 1964. The Court found that the undergraduate admissions
policy of awarding automatic ``points'' for race was mechanical, not
individualized, and made race a decisive factor in the admissions
process. Id. at 271-72, 274. As such, the Court held that the
undergraduate admissions policies were not sufficiently narrowly
tailored to meet the strict scrutiny standard. Id. at 270. Because the
policy did not provide individualized consideration of applicants but
rather resulted in the admission of nearly every qualified applicant of
``underrepresented minority'' status, it was not narrowly tailored in
the manner required by previous jurisprudence to not violate the Equal
Protection Clause of the Fourteenth Amendment and Title VI of the Civil
Rights Act of 1964. Id.
In 2016, in Fisher v. University of Texas, 579 U.S. 365 (2016), the
Supreme Court again addressed whether the Equal Protection Clause of
the Fourteenth Amendment permits the consideration of race in
undergraduate admissions decisions. The Court held that the race-
conscious admissions program in use at the time by the University of
Texas was lawful under the Equal Protection Clause. Id. at 388. That
admissions program had been carefully crafted in light of Grutter, with
the goal of providing the educational benefits of a diverse student
body. The court found that the University had met its burden of showing
that the admissions policy was narrowly tailored, although it noted
that it ``remains an enduring challenge to our Nation's education
system to reconcile the pursuit of diversity with the constitutional
promise of equal treatment and dignity.'' Id. at 368. The court
observed that the University must continue to use its data about the
manner in which different approaches to admissions may foster diversity
or instead dilute it to scrutinize the fairness of its admissions
program, to assess whether the changing demographics have undermined
the need for a race-conscious admissions policy, and to study the
positive and negative effects of its affirmative action measures. Id.
Most recently, the Supreme Court held in Students for Fair
Admissions, Inc. v. President and Fellows of Harvard College, 600 U.S.
181 (2023), that the admissions policies of Harvard College and the
University of North Carolina had employed unlawful racial
discrimination in violation of Title VI of the Civil Rights Act of 1964
and the Equal Protection Clause of the Fourteenth Amendment,
respectively. The Court discussed the exacting nature of the strict
scrutiny standard necessary to justify racial discrimination under the
Equal Protection Clause, explaining that, ``[o]ur acceptance of race-
based state action has been rare for a reason. Distinctions between
citizens solely because of their ancestry are by their very nature
odious to a free people whose institutions are founded upon the
doctrine of equality. That principle cannot be overridden except in the
most extraordinary case.'' Id. at 208 (internal cites omitted).
Ultimately, the Court found that these universities' race-based
admissions policies did not survive strict scrutiny because they ``lack
sufficiently focused and measurable objectives warranting the use of
race, unavoidably employ race in a negative
[[Page 56815]]
manner, involve racial stereotyping, and lack meaningful end points.''
Id. at 230. The Court found flaw with the dissenting opinions (which
would have upheld the race-based admissions programs based on remedying
the effects of societal discrimination), stating that ``[i]n the years
after Bakke, the Court repeatedly held that ameliorating societal
discrimination does not constitute a compelling interest that justifies
race-based state action.'' Id. at 226.
Explanation of Provisions
These proposed regulations would provide that all forms of racial
discrimination in education, regardless of the intent behind or the
legality of such discrimination (for example, where such discrimination
is defended as serving remedial or diversity-related objectives), are
against a fundamental public policy of the United States and thus
preclude a school's exemption from Federal income tax under section
501(c)(3). In so doing, the proposed regulations would make clear that
discriminating based on race, color, or national or ethnic origin for
any purpose by a private school is contrary to a fundamental public
policy of the United States. This public policy is evidenced by
antidiscrimination law such as the Equal Protection Clause of the
Fourteenth Amendment, the Civil Rights Act of 1964, Supreme Court case
law such as Brown to Runyon to Bob Jones to Students for Fair
Admissions, and the actions taken by the Executive Branch to ensure
racial nondiscrimination is instituted throughout the United States.\3\
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\3\ See, e.g., Executive Order 10730 (22 FR 7628; Sep. 24, 1957)
(authorizing the use of the National Guard to enforce the
desegregation of public schools in Little Rock, Arkansas); Executive
Order 14173 (90 FR 8633; Jan. 21, 2025) (directing agency heads to
create plans to deter illegal discrimination, including at
institutions of higher education); Executive Order 14280 (90 FR
17533; April 23, 2025) (directing the Secretary of Education and
Attorney General to take action aimed at preventing racial
discrimination in school disciplinary systems).
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If these regulations are finalized as proposed, certain portions of
Rev. Proc. 75-50, concerning private schools favoring racial minority
groups with respect to admissions, facilities and programs, and
financial assistance, would be incompatible with the new rules.
Accordingly, Rev. Proc. 75-50, as modified by Rev. Proc. 2019-22, would
be modified by deleting the second sentence of section 3.02 and the
third and fourth sentences of section 4.05. Consistent with these
proposed rules, these modifications would take effect with respect to
taxable years of private schools beginning after May 31, 2027, which is
expected to be after the date of publication of final regulations in
the Federal Register. Apart from these modifications, Rev. Proc. 75-50
(as modified by Rev. Proc. 2019-22) would remain in effect.
For the avoidance of any doubt, the proposed regulations would not
preclude a private school from maintaining a religious mission,
curriculum, or program of observance, or from selecting students on the
basis of religious affiliation or membership. Use of a religiously
based selection criterion does not become discrimination on the basis
of race, color, or national or ethnic origin merely because members of
the relevant religious community may also share ancestry or ethnic
characteristics (so long as the selection criteria is based solely on
religion and not on shared ancestry or ethnic characteristics).
Similarly, the proposed regulations would not disturb the continued
ability of an organization (including a private school) to take actions
or adopt policies intended to eliminate prejudice and discrimination,
consistent with existing Sec. 1.501(c)(3)-1(d)(2), provided the
organization achieves these purposes by means other than actions or
policies that discriminate on the basis of race, color, or national or
ethnic origin.
Incorporating the long-standing holding of Rev. Rul. 71-447 in
regulatory text and removing the language in Rev Proc. 75-50 as to the
favoring of racial minority groups to further a school's racially
nondiscriminatory purpose would allow for more consistent application
of Federal tax law across the United States and make clear to all
private schools (that is, all private primary and secondary schools,
colleges, professional or trade schools, and universities) the need to
eliminate all impermissible racially discriminatory policies
incompatible with the benefit of Federal income tax exemption. The
proposed regulations would achieve this result by stating a clear,
enforceable standard: private schools cannot qualify as ``operated
exclusively for exempt purposes'' within the meaning of section
501(c)(3) if they adopt, maintain, or enforce any policy or practice
that discriminates on the basis of race, color, or national or ethnic
origin in the administration of any educational policy, admissions
policy, scholarship or loan program, athletic program, or other school-
administered or supported program.
The proposed regulations would achieve these objectives by adding a
new Sec. 1.501(c)(3)-2 to 26 CFR part 1.
Proposed Sec. 1.501(c)(3)-2(a) would provide the general rule that
a private school (as defined in proposed Sec. 1.501(c)(3)-2(c)) must
be operated exclusively for exempt purposes (within the meaning of
Sec. 1.501(c)(3)-1(d)) to be an organization described in section
501(c)(3). It would also provide that a private school that fails to
satisfy the nondiscrimination requirement of proposed Sec.
1.501(c)(3)-2(b) will not be exempt from Federal income tax under
section 501(c)(3) with respect to taxable years beginning after May 31,
2027, which is after the date final regulations are expected to be
published in the Federal Register.
Proposed Sec. 1.501(c)(3)-2(b) would provide that a private school
is not ``operated exclusively for exempt purposes'' if it adopts,
maintains, or enforces any policy or practice that discriminates on the
basis of race, color, or national or ethnic origin in the
administration of any educational policy, admissions policy,
scholarship and loan program, athletic program, or other school-
administered or school-supported program. Proposed Sec. 1.501(c)(3)-
2(b) would add that, for this purpose, policies or practices that
discriminate on the basis of race, color, or national or ethnic origin
include policies or practices that so discriminate for any purpose.
Lastly, proposed Sec. 1.501(c)(3)-2(c) would provide that for
purposes of proposed Sec. 1.501(c)(3)-2, the term ``private school''
means an organization that (determined without regard to the
nondiscrimination requirement of paragraph (b)) is described in section
501(c)(3) and classified as an educational organization described in
section 170(b)(1)(A)(ii) (that is, any private primary or secondary
school, college, professional or trade school, or university). The term
does not include a governmental unit, an agency or instrumentality of a
governmental unit, or an organization owned or operated by an agency or
instrumentality of a governmental unit.
The proposed regulations are intended to clarify the law applicable
to qualification for the Federal tax exemption of private schools,
which would eliminate ambiguity and ensure consistent application
across all private schools. The proposed regulations would also provide
administrative certainty for IRS personnel and ensure that Federal
income tax exemption does not benefit racially discriminatory practices
in education.
Proposed Applicability Date
The Treasury Department and the IRS expect to finalize these
regulations, with
[[Page 56816]]
any necessary modifications based on timely comments received, in
advance of May 31, 2027. These regulations are proposed to apply to
taxable years of private schools beginning after May 31, 2027. This
proposed applicability date will allow any private schools that may
need to amend their existing policies, including admissions or
scholarship policies, to do so before the beginning of any taxable year
to which the final regulations are expected to apply.
Special Analyses
I. Regulatory Planning and Review
Executive Orders 12866 and 13563 direct agencies to assess costs
and benefits of available regulatory alternatives and, if regulation is
necessary, to select regulatory approaches that maximize net benefits
(including potential economic, environmental, public health and safety
effects, distributive impacts, and equity). Executive Order 13563
emphasizes the importance of quantifying both costs and benefits,
reducing costs, harmonizing rules, and promoting flexibility.
These proposed regulations have been designated by the Office of
Management and Budget's (OMB's) Office of Information and Regulatory
Affairs (OIRA) as subject to review under section 6(b) of Executive
Order 12866 pursuant to the Memorandum of Agreement (July 4, 2025)
between the Treasury Department and the Office of Management and Budget
regarding review of tax regulations. OIRA has determined that the
proposed rulemaking is significant and subject to review under
Executive Order 12866 and section 1(b) of the Memorandum of Agreement.
Accordingly, the proposed regulations have been reviewed by OMB.
A. Need for Regulation
The proposed regulations would provide that a private school which
discriminates on the basis of race, color, or national or ethnic origin
in the administration of its policies is not operated ``exclusively for
charitable purposes.'' Therefore, a private school which engages in
racial discrimination cannot qualify for exemption from Federal income
tax. Consistent with recent developments in the law,\4\ these
regulations hold that racial discrimination in education is
impermissible, regardless of its intent (for example, to ameliorate the
effects of past racial discrimination).
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\4\ See Students for Fair Admissions v. President and Fellows of
Harvard College, 600 U.S. 181 (2023) (SFFA).
---------------------------------------------------------------------------
B. The Statute and the Proposed Regulations
The proposed regulations would provide that a private school cannot
meet the definition of an organization exempt from Federal income tax
if it discriminates on the basis of race, color, or national or ethnic
origin in administration of its educational, admissions, scholarship,
athletic, or other policies. It would further define race-based action
for the purpose of ameliorating societal discrimination as a form of
discrimination. These regulations would apply to private primary,
secondary, preparatory, or high schools, as well as colleges and
universities, for taxable years beginning after May 31, 2027.
C. Baseline
The Treasury Department and the IRS have assessed the benefits and
costs of the proposed regulations relative to a no-action baseline
reflecting anticipated Federal income tax-related behavior in the
absence of these proposed regulations.
D. Affected Entities and Taxpayers
The Treasury Department and the IRS estimate that the proposed
regulations may affect the 18,000 private elementary, secondary, and
post-secondary schools in the United States that currently qualify for
tax exempt status and the 750,000 students attending these schools who
may qualify for scholarships allocated on the basis of racial, ethnic,
or national identity.\5\ In addition, the Treasury Department and the
IRS estimate that the proposed regulations may also affect taxpayers
who donate to scholarship funds administered by private schools, and
that use racial criteria to determine eligibility to receive
scholarship funds. The Treasury Department and the IRS do not have
readily available parameters and models to quantify the number of
taxpayers who make charitable contributions to support race-based
scholarship funds administered by private schools.
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\5\ The Treasury Department and the IRS do not collect
information on race or ethnicity. The number of students potentially
qualifying for scholarships based on race or ethnicity is estimated
using a survey conducted by the GAO, (Linda G. Morra, ``Higher
Education: Information on Minority-Targeted Scholarships,'' U.S.
Government Accountability Office (GAO), HEHS-94-77, January 14,
1994; last accessed February 19, 2026. <a href="https://www.gao.gov/assets/hehs-94-77.pdf">https://www.gao.gov/assets/hehs-94-77.pdf</a>).
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E. Economic Effects of the Proposed Regulations
As postsecondary schools have already changed their admissions
policies following the Supreme Court's decision in Students for Fair
Admissions (SFFA), the Treasury Department and the IRS anticipate that
all economic effects of this proposed regulation on postsecondary
schools will follow from the requirement to apply such definition of
discrimination to the administration of scholarship and loan policies.
The Treasury Department and the IRS expect that all private primary
and secondary schools will adjust their admissions criteria to conform
to the proposed regulations, so that they may retain their tax-exempt
status.\6\ The proposed regulations provide that to maintain tax exempt
status, schools may not discriminate on the basis of race in their
admissions policies, but the Treasury Department and the IRS are not
aware of any data that would provide the extent to which private
primary and secondary schools currently discriminate on the basis of
race and ethnicity when admitting students. Further to the extent that
the number of primary and secondary students being educated is
unchanged, it is expected that the change in the racial composition of
primary and secondary students among public and private primary and
secondary schools will have a minimal effect on primary and secondary
student outcomes or economic growth in general. The Treasury Department
and the IRS also do not have the data to model the cost to schools
(that currently discriminate based on race or ethnicity) of changing
admission criteria to maintain compliance. Low-cost options to maintain
compliance may be available to many schools, but some schools may
choose higher cost options in order to
[[Page 56817]]
meet other objectives. To the extent that primary and secondary schools
have preemptively adjusted admission criteria in the wake of the SFFA
decision regarding postsecondary schools and to the extent that low
cost compliance options are available (even if not chosen), compliance
costs with regard to private primary and secondary school admission
would be minimal.
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\6\ Private primary and secondary schools were not directly
affected by SFFA. However, following SFFA, several prominent
advisors to private primary and secondary schools anticipated that
this decision would ultimately come to apply to K-12 private schools
as well, and advised schools to adapt their admissions processes
accordingly. Treasury and the IRS therefore anticipate that a subset
of these schools have already changed their admissions policies to
reflect a definition of discrimination close to the one in the
proposed rule. Smith, Kristin L. 2023. ``6 Steps for Private and
Independent Schools in the Wake of the SCOTUS Affirmative Action
Ruling.'' <a href="https://www.fisherphillips.com/en/insights/insights/private-and-independent-schools-scotus-affirmative-action-ruling">https://www.fisherphillips.com/en/insights/insights/private-and-independent-schools-scotus-affirmative-action-ruling</a>.
Pass, Caryn G., Grace H. Lee, Janice P. Gregerson, and Ashley E.
Sykes. 2023. ``No More Affirmative Action: What Does the Supreme
Court's Decision Mean for Independent Schools?'' <a href="https://www.venable.com/insights/publications/2023/07/no-more-affirmative-action-what-does">https://www.venable.com/insights/publications/2023/07/no-more-affirmative-action-what-does</a>.
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The proposed regulations are not expected to affect private school
athletic programs where inclusion is generally based on athletic
ability, not race or ethnicity. Further, while the proposed regulations
might also affect any other school-supported programs or education
policies administered by private schools, the Treasury Department and
the IRS assume that any economic effects arising from this relatively
narrow, miscellaneous group of activities would be insignificant.
The proposed regulations are expected to have three types of
economic effects on private school financial aid policies. First,
private schools may incur some legal and administrative costs as they
endeavor to comply with the proposed regulations. Second, the proposed
regulations may affect the distribution of scholarship and loan funds
among the population of students. Third, the proposed regulations may
affect the charitable giving behavior of donors who wish to provide
scholarships or loans where race, ethnicity, or national origin are
included in the set of eligibility criteria. In all cases, if these
nondiscrimination rules are finalized as proposed, the Treasury
Department and the IRS expect that private schools will comply in order
to maintain their tax-exempt status. This assumption is based on the
observed compliance with the Supreme Court ruling in SFFA.\7\
---------------------------------------------------------------------------
\7\ Prior to SFFA, experts anticipated that a race-blind
admissions policy would impact the racial composition at only the
most selective institutions, reducing the share of their student
body which comes from historically underrepresented racial, ethnic,
or national groups, and correspondingly increasing the share of
other students represented on these campuses (Reber, Goodman, and
Nagashima (2023)). Recent research finds evidence that SFFA has had
this expected effect on admissions. In the year following SFFA, the
shares of Black, Native American, Hispanic/Latino, Native Hawaiian,
and Pacific Islander students enrolled at the most selective schools
fell (Snider, 2026). These findings are corroborated by Bloem et al.
(2026), which further shows that these students instead enrolled at
less-selective schools, while the highest-achieving students
belonging to other races, ethnicities, and nationalities, and
residing in low-income neighborhoods, were more likely to attend
``Ivy Plus'' colleges following SFFA. As the anticipated effect of
this policy has thus far been borne out in empirical data, this
evidence is consistent with compliance with the Supreme Court ruling
in SFFA. Bloem, Michael D., Ashley Edwards, J. Parker Goyer, Jessica
Howell, Xiaowen Hu, Michael Hurwitz, Samuel J. Imlay, Jennifer Ma,
and Matea Pender. 2026. ``College Enrollment Patterns After SFFA v.
Harvard.'' EdWorkingPaper: 26-1392. Retrieved from Annenberg
Institute at Brown University: <a href="https://doi.org/10.26300/6a7w-bq06">https://doi.org/10.26300/6a7w-bq06</a>.
Reber, Sarah, Gabriela Goodman, and Rina Nagashima. 2023.
``Admissions at most colleges will be unaffected by Supreme Court
ruling on affirmative action.'' <a href="https://www.brookings.edu/articles/admissions-at-most-colleges-will-be-unaffected-by-supreme-court-ruling-on-affirmative-action/">https://www.brookings.edu/articles/admissions-at-most-colleges-will-be-unaffected-by-supreme-court-ruling-on-affirmative-action/</a>. Snider, Emily. 2026. ``The Impact of
the 2023 Students for Fair Admissions v. Harvard Decision on
Undergraduate Demographics.'' EdWorkingPaper: 26-1471. Retrieved
from Annenberg Institute at Brown University: <a href="https://doi.org/10.26300/98fw-8558">https://doi.org/10.26300/98fw-8558</a>.
---------------------------------------------------------------------------
1. Compliance Costs for Private Schools
Private schools may incur some legal and administrative costs as
they endeavor to comply with the proposed regulations. These costs will
depend, in part, on the legal circumstances under which a race-based
scholarship was created. In the event that a race-based scholarship was
endowed by a donor, whose letter of intent explicitly stated that
eligibility relies on race-based criteria, schools may need to work
with the donors, or the donors' heirs, to find an alternative set of
eligibility criteria for the scholarship recipients. This process will
incur administrative and legal costs. The Treasury Department and the
IRS do not have readily available parameters or models to precisely
assess the extent of such costs. However, only a minority of
scholarship dollars are restricted by the donor's intention:
scholarship dollars funded by any restricted endowment (restricted by
race, ethnicity or any other criterion) represent no more than 16
percent of total scholarship dollars.\8\
---------------------------------------------------------------------------
\8\ U.S. Department of Education, National Center for Education
Statistics, Integrated Postsecondary Education Data System (IPEDS),
Spring 2025, Finance component, retrieved on February 10, 2026, from
<a href="https://nces.ed.gov/ipeds/use-the-data">https://nces.ed.gov/ipeds/use-the-data</a>. This share represents the
share of all institutional grants to students which are funded by
endowments. Unfunded institutional grants include the amount awarded
to students from unrestricted institutional resources. Funded
institutional grants include the amounts awarded to students from
institutional resources restricted for the purpose of student aid,
such as scholarships and fellowships funded by gifts or endowment
return restricted for that purpose.
---------------------------------------------------------------------------
Most scholarships and loans offered by private schools are not
endowed by a donor with the express intent of restricting eligibility
based on race, ethnicity, or national origin. For these scholarships
and loans, private schools would have the latitude to revise
eligibility criteria to conform to the proposed regulation's definition
of racial nondiscrimination. In this case, private schools may use a
different mechanism for allocating scholarships and loans to
recipients, for example, using geographic or income-based criteria in
lieu of a racial or ethnic criterion to determine scholarship
eligibility. The shift to using a different mechanism is not expected
to result in significant compliance costs and may be the preferred
method for maintaining compliance while targeting scholarships and
loans to certain students.
2. Changes in Recipient Population
The proposed regulations may affect the distribution of private
school scholarship and loan funds among the population of students.
This would result in a change in the composition of the pool of
scholarship and loan recipients, but the total value of scholarships
and loans awarded, and the number of scholarship and loan recipients,
are not expected to change. The degree to which the composition of the
pool of scholarship and loan recipients changes may also be limited.
The Treasury Department and the IRS expect that donors may continue
to donate to private schools using alternative criteria, such as
income, geography, or first-generation student status. The use of these
alternative criteria results in a weaker relationship with race and
ethnicity and a stronger relationship with other indicators of
disadvantage such as income.\9\ The Treasury Department and the IRS
therefore anticipate that, should donors come to rely on alternative
criteria, their gifts would ultimately benefit a population of
scholarship recipients whose socioeconomic characteristics are similar
to, but do not precisely coincide with, those of the counterfactual set
of individuals who would have received scholarships in the absence of
the proposed rule.
---------------------------------------------------------------------------
\9\ Levine, Phillip, and Sarah Reber. 2023.``Can colleges afford
class-based affirmative action?'' Technical report, The Brookings
Institution. <a href="https://www.brookings.edu/articles/can-colleges-afford-class-based-affirmative-action/">https://www.brookings.edu/articles/can-colleges-afford-class-based-affirmative-action/</a>. Epple, Dennis, Richard Romano, and
Holger Sieg. ``Diversity and affirmative action in higher
education.'' Journal of Public Economic Theory 10.4 (2008): 475-501.
---------------------------------------------------------------------------
The Treasury Department and the IRS also expect that almost all
private schools, in order to maintain their tax-exempt status, will
adjust their scholarship and loan criteria to conform to the
regulations if finalized as proposed. To the extent the new criteria
used by private schools to distribute scholarships and loans among
their students (for example, income and geography) are correlated with
race and ethnicity, the change in the recipient population may be
limited. The Treasury Department and the IRS do not have readily
available parameters and models to more precisely assess the
correlation between race and ethnicity
[[Page 56818]]
and other possible criteria that may be used by private schools to
distribute scholarships and loans.
3. Charitable Giving Behavior of Donors
The Treasury Department and the IRS expect that the proposed
regulation may affect the charitable giving behavior of donors who wish
to provide scholarships or loans where race, ethnicity, or national
origin are included in the set of eligibility criteria. These donors
may find that eligibility criteria other than race, ethnicity, or
national origin, can also be well-suited to promoting educational
attainment for certain families. While the proposed rule does prevent
these donors from granting scholarships based on race, ethnicity, or
national origin through schools, these donors retain the ability to
fund other scholarships. By funding these alternative scholarships,
donors may achieve substantially similar outcomes--both for the
beneficiaries of their gifts, and with respect to their own tax
liability--under the proposed rule as they would have achieved in its
absence. As such, the Treasury Department and the IRS expect that the
regulation will have a negligible impact on this subset of charitable
donors.
II. Paperwork Reduction Act
The proposed regulations do not create new collection requirements,
as defined under the Paperwork Reduction Act (44 U.S.C. 35); and do not
alter any previously approved OMB information collection requirements
and their associated burden.
III. Regulatory Flexibility Act
The Secretary of the Treasury certifies that these proposed
regulations will not have a significant economic impact on a
substantial number of small entities pursuant to the Regulatory
Flexibility Act (5 U.S.C. chapter 6). This certification is based on
the fact that although these proposed regulations may affect as many as
18,000 private elementary, secondary, and post-secondary schools, the
proposed regulations would not impose new economically significant
requirements on a substantial number of small entities seeking Federal
income tax exemption other than legal requirements such entities likely
already comply with. The proposed regulations also would not impose a
collection of information on any entities (including small entities).
The economic effects of the proposed regulations would follow from the
administration of scholarship and loan policies by these private
schools, with effects on athletics and any other school-supported
programs or education policies administered by private schools being
insignificant.
Private schools may incur some legal and administrative costs as
they endeavor to comply with the regulations if finalized as proposed
to the extent of any race-based scholarships that are endowed by a
donor, whose letter of intent explicitly stated that eligibility relies
on race-based criteria. The income from a scholarship endowment is
restricted to fund scholarships, so the impact of eliminating or
transferring any such funds on the operating budget and investment
assets of the school would be minimal. To the extent that such private
schools have preemptively adjusted admissions and scholarship criteria
in the wake of the SFFA decision, any such effects would be attenuated
towards zero.
The Treasury Department and the IRS do not have readily available
parameters and models to precisely assess the extent to which affected
private schools would pursue shifting criteria, returning funds, or
maintaining funds without granting race-based scholarships, or the cost
of implementing such changes. However, only a minority of scholarship
dollars are restricted by the donor's intention: scholarship dollars
funded by any restricted endowment (restricted by race, ethnicity, or
any other criterion) represent no more than 16 percent of total
scholarship dollars.\10\ As such, the Treasury Department and the IRS
believe any legal and administrative costs to comply with the
regulations (if finalized as proposed) for those private schools with
existing endowed race-based funds would not have a significant economic
impact on a substantial number of small entities.
---------------------------------------------------------------------------
\10\ See Id.
---------------------------------------------------------------------------
Notwithstanding this certification that the proposed regulations
would not have a significant economic impact on a substantial number of
small entities, the Treasury Department and the IRS invite comments on
the economic impacts these proposed regulations may have on small
entities.
IV. Section 7805(f)
Pursuant to section 7805(f) of the Code, these proposed regulations
will be submitted to the Chief Counsel for Advocacy of the Small
Business Administration for comment on their impact on small business.
V. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates Reform Act of 1995 requires
that agencies assess anticipated costs and benefits and take certain
other actions before issuing a final rule that includes any Federal
mandate that may result in expenditures in any one year by a State,
local, or Tribal government, in the aggregate, or by the private
sector, of $100 million in 1995 dollars, updated annually for
inflation. These proposed regulations do not include any Federal
mandate that may result in expenditures by State, local, or Tribal
governments, or by the private sector, in excess of that threshold.
VI. Executive Order 13132: Federalism
Executive Order 13132 (Federalism) prohibits an agency from
publishing any rule that has federalism implications if the rule either
imposes substantial, direct compliance costs on State and local
governments, and is not required by statute, or preempts State law,
unless the agency meets the consultation and funding requirements of
section 6 of the Executive order. These proposed regulations do not
have federalism implications, do not impose substantial direct
compliance costs on State and local governments, and do not preempt
State law within the meaning of the Executive order.
Comments and Requests for a Public Hearing
Before these proposed regulations are adopted as final regulations,
consideration will be given to any comments that are submitted timely
to the Treasury Department and the IRS as prescribed in this preamble
under the ADDRESSES heading. The Treasury Department and the IRS
request comments on all aspects of the proposed regulations. Any
comments submitted will be made available at <a href="https://www.regulations.gov">https://www.regulations.gov</a> or upon request. A public hearing will be scheduled
if requested in writing by any person that timely submits electronic or
written comments. Requests for a public hearing are encouraged to be
made electronically. If a public hearing is scheduled, notice of the
date, time, and place for the hearing will be published in the Federal
Register.
Effect on Other Documents
If these rules are finalized as proposed, Rev. Proc. 75-50, as
modified by Rev. Proc. 2019-22, would be modified by deleting the
following sentences which are incompatible with the proposed rules:
1. The second sentence of section 3.02.
2. The third and fourth sentences of section 4.05.
[[Page 56819]]
Statement of Availability of IRS Documents
Rev. Rul. 71-447 and Rev. Proc. 75-50 were published in the
Internal Revenue Bulletin and are available from the Superintendent of
Documents, U.S. Government Publishing Office, Washington, DC 20402, or
by visiting the IRS website at <a href="https://www.irs.gov">https://www.irs.gov</a>.
Drafting Information
The principal author of these proposed regulations is the Office of
Associate Chief Counsel (Employee Benefits, Exempt Organizations, and
Employment Taxes). However, other personnel from the Treasury
Department and the IRS participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Proposed Amendments to the Regulations
Accordingly, the Treasury Department and the IRS propose to amend
26 CFR part 1 as follows:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for 26 CFR Part 1 continues to
read, in part, as follows:
Authority: 26 U.S.C. 7805 * * *
* * * * *
0
Par. 2. Section 1.501(c)(3)-2 is added to read as follows:
Sec. 1.501 (c)(3)-2 Racial nondiscrimination requirement for private
schools.
(a) In general. A private school (as defined in paragraph (c) of
this section) must be operated exclusively for one or more exempt
purposes (as defined in Sec. 1.501(c)(3)-1(d)) to be an organization
described in section 501(c)(3) of the Internal Revenue Code (Code). A
private school that fails to satisfy the nondiscrimination requirement
of paragraph (b) of this section is not an organization described in
section 501(c)(3) with respect to any taxable year of the private
school described in paragraph (d) of this section.
(b) Nondiscrimination requirement. A private school is not operated
exclusively for exempt purposes if it adopts, maintains, or enforces
any policy or practice that discriminates on the basis of race, color,
or national or ethnic origin in the administration of any educational
policy, admissions policy, scholarship or loan program, athletic
program, or other school-administered or school-supported program. For
purposes of this section, discrimination on the basis of race, color,
or national or ethnic origin includes any discrimination on the basis
of race, color, or national or ethnic origin for any purpose.
(c) Private school defined. For purposes of this section, the term
private school means an organization described in section 501(c)(3)
(determined without regard to the nondiscrimination requirement of
paragraph (b) of this section) and classified as an educational
organization described in section 170(b)(1)(A)(ii) of the Code. The
term private school does not include a governmental unit, an agency or
instrumentality of a governmental unit, or an organization that is
owned or operated by an agency or instrumentality of a governmental
unit. For purposes of this definition, the term governmental unit means
the United States, a State, an Indian Tribal government (within the
meaning of section 7701(a)(40) of the Code), the District of Columbia,
a possession of the United States, or a political subdivision of any of
the foregoing.
(d) Applicability date. This section applies with respect to the
taxable year of any private school beginning after May 31, 2027.
Frank J. Bisignano,
Chief Executive Officer.
[FR Doc. 2026-18127 Filed 9-3-26; 8:45 am]
BILLING CODE 4831-GV-P
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This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.