Position Papers, Letters and Petitions Signed By The Church of Scientology National Affairs Office

Discussion in 'News and Current Events' started by CommunicatorIC, Oct 6, 2018.

  1. Position Papers, Letters and Petitions Signed By The Church of Scientology National Affairs Office.

    In the past, I have individually cross-posted position papers, letters and petitions signed by the Church of Scientology National Affairs Office. I will continue to do so if I believe the paper, letter or petition is of sufficient importance or sufficient interest and deserves its own thread. The purpose of this thread is to memorialize those that don't satisfy that standard.

    As I've previously argued, it appears the purpose of these Church of Scientology National Affairs Office position papers, letters and petitions is to help it gain support from and form alliances with churches, religions, and civil rights organizations.

    To start:


    Church of Scientology National Affairs Office calls for sanctions against officers of officers of the People's Republic of China who allegedly committed atrocities in Xinjiang and Tibet.

    * * * * * BEGIN EXCERPT * * * * *

    The Honorable Steven Mnuchin
    Secretary of the Treasury
    1500 Pennsylvania Avenue Northwest
    Washington, D.C. 20220
    The Honorable Mike Pompeo
    Secretary of State
    2201 C Street Northwest
    Washington, D.C. 20520

    Dear Secretary Mnuchin and Secretary Pompeo:

    We, the undersigned organizations, urge you to sanction all Chinese officials responsible for the horrendous human rights situation in Tibet and Xinjiang, also known as East Turkestan. We commend the State Department for calling attention to this issue in its first-ever Ministerial to Advance Religious Freedom, and concur with the Ministerial’s Statement on China, which strongly urges “the Chinese government to protect the religious freedom of all individuals and to respect the human rights of all members of religious groups in accordance to China’s international commitments to respect freedom of religion.” We believe the United States can best pressure China by using the Global Magnitsky Human Rights Accountability Act to punish the officials responsible for these egregious human rights violations.

    Tibet and Xinjiang are considered “autonomous regions,” but in reality, they are entirely controlled by Beijing. The People’s Republic of China has made a mockery of human rights, and established concentration camps the likes of which are found elsewhere only in North Korea. The Chinese Communist Party (CCP) is engaged in a full-scale campaign of cultural genocide against the Tibetans and Uyghurs, and it is time for the United States to take action.

    According to the United Nations, the CCP has incarcerated 1 million Uyghurs in so-called “reeducation” camps, and as many as 2 million have been forced to undergo “reeducation and indoctrination.” The Congressional Executive Commission on China claims that this constitutes “the largest mass incarceration of a minority population in the world today.” Tahir Hamut, a Uyghur Muslim who left Xinjiang for the United States, recounted during the Ministerial how his people are “now living in horror” of being thrown into these camps, where they are beaten, tortured, and forced to consume alcohol and pork, both of which are anathema to observant Muslims.

    Mr. Hamut also said that “there are unprecedented restrictions on the religious lives of Uyghurs.” Even “free” Uyghurs living in their own homes face a life of fear and surveillance. During Ramadan, the CCP embeds officers in Uyghur homes to make sure they don’t pray or fast. Xinjiang is one of the most surveilled regions in the world, with the CCP investing more than $1 billion in security investment projects in the first quarter of 2018 alone. Officials like Chen Quanguo, Communist Party Secretary of Xinjiang and previous Party Secretary of Tibet, are directly responsible for carrying out these brutal orders from Beijing.

    The situation is just as bad in Tibet. Since invading and annexing Tibet in 1950, the CCP has murdered around 1 million Tibetans; destroyed 6,000 Buddhist monasteries; forced 100,000 Tibetans into exile; and ruined 80% of Tibet’s forests. The Chinese police state is so pervasive that Tibet has been described as “harder to visit than North Korea.” Yet the CCP is not content with merely controlling the Tibetans’ land; it must control their religion as well. For over half a century, the Dalai Lama has been living in exile from his homeland, and the Panchen Lama, who is the second most important religious authority in Tibetan Buddhism, was abducted by the Chinese over twenty years ago when he was only six years old; his current whereabouts are unknown. This state of oppression has tragically caused more than 150 Tibetans to lose all hope, and set themselves on fire to protest the abuses they face. China will continue its atrocious abuse of human rights in Tibet and Xinjiang until the free world pushes back. We must show those officials responsible for enslaving innocent people that neither they nor their assets are welcome in the United States until these abuses cease. By imposing stringent sanctions under the Global Magnitsky Act, the United States can send a powerful message that the world will not stand by as the CCP abuses its people.


    21st Century Wilberforce Initiative
    Bitter Winter
    Boat People SOS
    Buddhist Solidarity Association
    Center for Pluralism
    Center for Studies on New Religions
    Chen Guangcheng Foundation
    China Aid
    Christian Freedom International
    Christian Solidarity Worldwide
    Church of Scientology National Affairs Office
    Committee for Religious Freedom in Vietnam
    The Council of Peoples and Religions of Vietnam
    Initiatives for China
    International Campaign for Tibet
    International Christian Concern
    International Interfaith Peace Corps
    International Observatory of Religious Liberty of Refugees
    The Junior Sacerdotal of Caodai Council
    The Junior Sacerdotal Council of the Third Amnesty of God of Tay Ninh Holy See
    Keep Taiwan Free
    Lantos Foundation for Human Rights and Justice
    Love Your Neighbor Community
    Magnitsky Global Justice Campaign
    Religious Freedom Institute
    Students for a Free Tibet
    Union of Councils for Jews in the former Soviet Union
    Uyghur American Association
    Uyghur Human Rights Project
    Victims of Communism Memorial Foundation
    Vietnam Coalition Against Torture
    Vietnam Committee on Human Rights
    World Uyghur Congress

    * * * * * END EXCERPT * * * * *
  2. Church of Scientology National Affairs Office Calls on US State Department to Pressure Bahrain and allow Hassan Mushaima Access to Healthcare.

    * * * * * BEGIN EXCERPT * * * * *

    NGOs call on US State Department to Pressure Bahrain and allow Hassan Mushaima access to healthcare

    on September 10, 2018

    On Monday, 10 September 2018, Americans for Democracy & Human Rights in Bahrain (ADHRB) and 13 human rights and faith organizations sent a letter to US Secretary of State Mike Pompeo calling the State Department’s attention to the abuse of Hasan Mushaima, a 70-year-old political prisoner in Bahrain. Mushaima is one of Bahrain’s most prominent political activists and religious thinkers who is serving a life sentence in Bahrain’s infamous Jau Prison. Continue reading for the text of the letter, or click link for a PDF of the letter.

    10 September 2018

    Hon. Mike Pompeo
    United States Secretary of State
    United States Department of State
    2201 C Street NW
    Washington, DC 20520

    Dear Secretary Pompeo,

    We, the undersigned human rights and faith organizations, write to call your attention to the abuse of political prisoner Hassan Mushaima, age 70, at the hands of the Bahraini government. Mushaima is one of Bahrain’s most prominent political activists and religious thinkers who is serving a life sentence in Bahrain’s infamous Jau Prison. As his sentence has progressed, his condition has increasingly deteriorated without access to proper medical care. Since his son has taken up a hunger strike outside of the Bahraini embassy in the United Kingdom, Bahraini authorities have continued to ignore and largely neglect the medical needs of Mushaima. As Mushaima’s health continues to deteriorate, it is imperative that the United States call on the Government of Bahrain to allow Mushaima full and unrestricted access to medical care, as well as proper treatment while in prison in line with international standards.

    Prior to his arrest, Hassan Mushaima served as Secretary-General of the al-Haq movement for Liberty and Democracy. He is the co-founder and former Vice President of al-Wefaq National Islamic Society – Bahrain’s largest political opposition group – that the government forcibly dissolved in 2016. He was arrested following the crackdown on Bahrain’s 2011 peaceful protest movement on charges of “attempting to overthrow the monarchy,” and subsequently sentence to life in prison. With his sentence, he has joined ranks of a dozen other high profile human rights defenders, political activists, and religious clerics who have all been subjected to poor treatment and abuse in Jau Prison, and all of whom are from the kingdom’s majority Shia Muslim community.

    In Jau, Mushaima has been denied access to necessary healthcare for a myriad of chronic illnesses. He has a history of cancer, having been diagnosed with and treated for stage four follicular lymphoma in 2010. Despite his remission, the chances that it could return calls for necessary regular cancer screenings. While in Jau, the Bahraini authorities have refused to provide these critical screenings, putting Mushaima’s life in peril – his last screening was in September 2016, and there have been no screenings or update on his cancer since. He also suffers from high blood pressure, gout, and diabetes. Despite clear need for consistent medical treatment, Mushaima has been prohibited to see any physician since March 2017. Nor have his medications been regularly administered throughout his sentence, lest he be in shackles to obtain his required medications. On 29 July 2018, he reported that his diabetes medication was entirely depleted, leaving him to resort to self-administered shots of insulin to try and regulate his blood sugar levels.

    The abuse Mushaima has faced under Jau Prison officials, unfortunately, extends even further than the deprivation of critical medical care. In addition to denial of treatment, in October of 2017, prison authorities subjected Mushaima to an unnecessary search and inspection, despite no history of violence. This strip search also coincided with the arbitrary confiscation of his personal items, including religious texts, notes, and phone credit cards. Mushaima and the other high profile prisoners have faced intense religious discrimination by Bahraini authorities, which has included the shaving of heads and beards of Shia clerics and the disruption of prayer rituals. Jau Prison authorities have made sure to attack every aspect of Mushaima’s identity as he serves his sentence, from his chronic illnesses to his faith.

    In addition to grave concerns regarding Hassan Mushaima’s health in Jau, we also raise the case of his son, Ali Mushaima, who began a hunger strike outside of the Bahraini embassy in London on August 1st, 2018 to protest his father’s abuse and denial of unrestricted medical care. Ali says his hunger strike will continue until the Bahraini authorities provide his father with full, unrestricted medical care unencumbered by shackles, family visitation, and the return his religious texts. However, even Ali’s demands have been met with harassment by the Bahraini government. On 12 August, a sleeping Mushaima was doused with an unknown foamy liquid thrown from the balcony of the Bahraini embassy in London, which also caused him to fear that he been assaulted with acid. When British law enforcement arrived and attempted to contact Embassy officials, no Bahraini representatives responded. The perpetrator and the liquid have not yet been identified, but Ali fears it was an attempt by Bahraini officials to end his hunger strike or silence him. After being hospitalized briefly at the one-month anniversary of his strike, Ali continues to protest on behalf of his father’s rights to healthcare, humane treatment, family visits and access to books and personal effects.

    As the health of both father and son become more dire, we call on the United States Department of State to publicly call on the Government of Bahrain to provide immediate, unrestricted access to medical care and to all necessary medications for Hassan Mushaima in accordance with Bahrain’s obligation to provide fair treatment of prisoners, as well as the full respect of his religious freedom by returning all personal items and religious texts. Finally, the United States should call for an end to the arbitrary imprisonment of prisoners of conscience, and an end to the over-incarceration of the Bahraini Shia, in line with its espoused commitment to religious freedom and human rights.



    Americans for Democracy & Human Rights in Bahrain (ADHRB)
    Center for Pluralism
    Church of Scientology National Affairs Office
    Citizen Power Initiatives for China
    International Christian Concern
    Mission Africa International
    Red Eagle Enterprises
    Religious Freedom Coalition
    South Asia Minorities Alliance Foundation
    The Junior Sacerdotal of Caodai Council
    The Russian Orthodox Autonomous Church of America
    The Voice of Karachi
    The Way to Happiness Association of Florida


    Ms. Farahnaz Ispahani
    Global Fellow,
    Woodrow Wilson International Center for Scholars and Senior Fellow, Religious Freedom Institute

    * * * * * END EXCERPT * * * * *
  3. Church of Scientology National Affairs Office Urges US Congress to Oppose Inclusion of the Stop the Importation and Trafficking of Scheduled Analogues (SITSA) (H.R. 2851/S. 1327) Act in the House (H.R. 6) and Senate Opioid Package (S. 2680).

    * * * * * BEGIN EXCERPT * * * * *

    September 20, 2018 9:00AM EDT

    Drug Policy Coalition Urges US Congress to Oppose Inclusion of the Stop the Importation and Trafficking of Scheduled Analogues (SITSA) (H.R. 2851/S. 1327) Act in the House (H.R. 6) and Senate Opioid Package (S. 2680).

    The Honorable Paul Ryan
    Speaker of the House
    US House of Representatives
    1233 Longworth House Office Building
    Washington, D.C. 20515

    The Honorable Mitch McConnell
    Majority Leader
    US Senate
    317 Russell Office Building
    Washington, DC 20515

    The Honorable Nancy Pelosi
    Minority Leader
    US House of Representatives
    233 Cannon Office Building
    Washington, DC 20515

    The Honorable Chuck Schumer
    Minority Leader
    US Senate
    322 Hart Office Building
    Washington, DC 20515

    Dear Speaker Ryan, Majority Leader McConnell, Minority Leader Pelosi, and Minority Leader Schumer,

    We, the undersigned organizations, write to express our opposition to the inclusion of the Stop the Importation and Trafficking of Scheduled Analogues (SITSA) (H.R. 2851/S. 1327) in any final compromise legislation between the House opioid package (H.R. 6) and the Senate opioid package (S. 2680).

    In June 2018, many of us signed a letter to the House of Representatives urging members to vote against SITSA in the House. Our opposition to this legislation remains unchanged as Congress attempts to reconcile the differences between the opioid legislative packages passed by the House and Senate.

    While synthetic opioid overdoses are a very real problem, we believe that including SITSA in a final bill will ultimately prove ineffective in curbing our ongoing epidemic. Instead, SITSA will broadly expand penalties for drug offenses, concentrate power within the Department of Justice (DOJ), punish people who lack criminal intent, and overcriminalize certain behavior.

    Although SITSA passed the House, it has not been without strong Congressional opposition. The majority of House Democrats did not support the measure and many Republicans opposed it.[1] House Democratic Whip Steny Hoyer commented that “this legislation lacks clarity that could result in thousands of Americans being incarcerated, potentially for life sentences, thus exacerbating an already over-populated prison system. …[T]hose suffering from opioid addiction need treatment and proper medical care, not more laws that will simply put them behind bars."[2] Further, the House Liberty Caucus produced a statement detailing the extensive and irreversible harms of the past drug war, and implored that SITSA not be employed to revive the criminalization approach to a public drug crisis, as it has “eroded federalism, eviscerated numerous individual rights, entrenched severe discrimination in our criminal justice system, and failed to meaningfully limit the proliferation of illicit drugs.”[3] Those on both sides of the political spectrum recognize the damaging impact that SITSA could have should it pass, and wish to see drug policies that are health-centered.

    SITSA has also not passed the Senate, nor was it even marked up in the Judiciary Committee. To add this legislation to a final opioid legislative package would be to ignore the will of the Senate, denying members of the Judiciary Committee a say on issues in their jurisdiction. It could greatly complicate the passage of a final opioid package. Finally, many members of Congress have been working hard to reach agreement on criminal justice reform legislation that would reduce sentences for drug offenses. This bill would undermine these efforts by taking an approach synonymous with the failed war on drugs.

    SITSA would give the attorney general virtually unlimited authority to create new drug crimes that carry lengthy, expensive prison sentences. Deciding what is a crime and how it should be punished is Congress’s duty and should not be delegated to an unelected executive branch official. While the attorney general may currently schedule substances, the power to do so is carefully constrained. Currently, the DOJ must obtain the Department of Health and Human Services’ (HHS) approval for scheduling a drug. This is reasonable, as HHS’s drug experts offer informed and data-driven opinions as to which substances belong on each drug schedule. Under SITSA, the Attorney General would be required to consider HHS comments only before permanently classifying substances. In addition to the nearly unfettered ability to permanently schedule synthetic drugs, should SITSA pass the attorney general would have the ability to temporarily schedule drugs for nearly twice as long as currently permitted under law – 5.5 years instead of the current 3 – with no input from HHS.

    The proposed changes to the scheduling process under SITSA greatly threaten the American principles of balanced powers. SITSA would grant the attorney general – an unelected government actor – the ability to schedule drugs without oversight from medical professionals while consequently undermining Congress’ responsibility to create criminal law.

    SITSA would also overcriminalize synthetic drugs by penalizing individuals who lack any criminal intent. Under SITSA, individuals would face criminal charges and long sentences even if they did not know that they possessed or distributed a particular substance or that the substance had been scheduled, temporarily or permanently. Fentanyl and its analogues are just one example of how we already punish drug offenders with no criminal intent. In December 2017, Robert Perez, U.S. Customs and Border Patrol, testified that “[t]he majority of U.S. trafficked illicit fentanyl is produced in other countries such as China, and is principally smuggled through international mail facilities (IMFs), express consignment carrier facilities (ECCFs, e.g. FedEx and UPS), or through POEs along the Southern land border.” By the time that low-level sellers (who will undoubtedly bear the brunt of SITSA’s punishments) receive drugs including fentanyl or its analogues, most do not know what those drugs actually contain. They are often oblivious to the true content of their product, unknowingly and unintentionally providing users with the deadly drug fentanyl. We believe that any drug offense should require a culpable mental state. SITSA defies this principle, treating low-level dealers with tainted product as if they were knowingly distributing fentanyl-laced substances.

    Finally, criminalizing more drugs that trigger harsh penalties does not deter people with substance use disorders from using or buying drugs. Longer sentences do not deter drug use or drug crime; rather, it is the certainty that an individual will be caught and punished quickly that deters criminal behavior. A belief that harsh penalties, such as the 10-year maximum for a first offense of possession with intent of a synthetic substance, deter the drug trade also ignores the impaired reasoning processes of those struggling with addiction. Since the 1980s, the United States has had tough penalties for heroin,fentanyl, and fentanyl analogue use and distribution, yet opioid consumption has actually increased since that time.

    While health and public safety do not often have a price tag, it would behoove Congress to consider SITSA’s costs and benefits. SITSA will apply long drug sentences to more people, forcing taxpayers to pay for an increased prison population. Longer sentences and bigger prison populations do not yield the same public safety benefits as policies that would decrease the demand for drugs. Investing in treatment and public health would be a far more effective investment of taxpayer money.

    The drug policies of the 1980s and 1990s did not prevent the opioid epidemic or stop synthetic drug use. Congress has shown a continued commitment to righting these wrongs and using more effective strategies to combat and contain drug use and drug epidemics. SITSA would be a major step in the wrong direction. This bill defies our American principles of a balanced government in the pursuit of policy prescriptions proven to be ineffective -- namely, lengthy prison sentences that apply to those who have drug use issues. We ask that both chambers of Congress focus on policies that will increase the availability of drug treatment and reserve taxpayer dollars for more effective public health strategies, not more criminalization.

    American Civil Liberties Union
    AIDS Action Committee of Massachusetts
    Baltimore Harm Reduction Coalition
    Church of Scientology National Affairs Office
    Due Process Institute
    Drug Policy Alliance
    Federal Public and Community Defenders
    Friends Committee on National Legislation
    Human Rights Watch
    Iowa Harm Reduction Coalition
    Justice Strategies
    National Alliance of State and Territorial AIDS Directors
    National Association of Criminal Defense Lawyers
    National Association of Social Workers (NASW)
    National Center for Lesbian Rights
    National Viral Hepatitis Roundtable
    NETWORK Lobby for Catholic Social Justice
    North Carolina Harm Reduction Coalition
    Open Aid Alliance
    Reframe Health and Justice
    R Street Institute
    Safer Foundation
    Students for Sensible Drug Policy
    The Sentencing Project
    Washington Office on Latin America




    * * * * * END EXCERPT * * * * *
  4. The Church of Scientology National Affairs Office joins GLAD (GLBTQ Legal Advocates & Defenders), Human Rights Watch, the NAACP, the Southern Poverty Law Center and 80+ Organizations to Object to Proposed Fee to Protest on the National Mall.

    As I've previously argued, it appears the purpose of these Church of Scientology National Affairs Office position papers, letters and petitions is to help it gain support from and form alliances with churches, religions, and civil rights organizations.

    * * * * * BEGIN EXCERPT * * * * *

    October 15, 2018

    Mr. Brian Joyner
    Chief of Staff, National Mall and Memorial Parks
    National Park Service
    900 Ohio Drive SW
    Washington, DC 20024

    Dear Mr. Joyner:

    We write to express our deep concern over proposed rulemaking RIN 1024-AE45, issued August 7, 2018, which would revise the National Park Service’s protest permitting process regarding demonstrations at the National Mall, Memorial Parks, and President’s Park.

    This proposal would infringe on Americans’ rights to free speech and assembly. Forcing Americans to pay to lawfully assemble at our most iconic and politically significant sites places a financial barrier that precludes equal opportunity and access, dissuading and prohibiting Americans from demonstrating. The ability to afford fees for permits must not be a factor in who gets the opportunity to protest on these public lands. Introducing fees for First Amendment demonstrations would represent an overwhelming departure from American values.

    We strongly urge you to revise the proposed rule and maintain access to vibrant, participatory democracy for all Americans regardless of socioeconomic status or support from wealthy donors. Protesting is a cornerstone of American democracy. The First Amendment of the Constitution guarantees “Congress shall make no law … abridging the freedom of speech … or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.”

    Over centuries, Americans have come together from near and far and lifted their voices, from Rev. Dr. Martin Luther King Jr.’s “I Have a Dream” speech advancing the civil rights movement to the 2017 Women’s March, the largest demonstration in American history. Americans have cried out signifying ardent diversity of thought on a wide variety of issues spanning from war and peace to the economy, the environment, civil rights, human rights, and more. There is a fundamental personal dignity in protest—the insistence that one’s voice matters. Protesting is also a patriotic act, as Americans show up to help steer the path of our country. As we work to fulfill the promise of this country, we must never restrict access to the public lands surrounding its halls of power.

    Thank you for your commitment to preserving our cultural history and natural resources. As you work to manage an increase in requests for permits and maintain your commitment to preserving visitor experience, resource protection, and public safety, we trust you will reconsider this proposal and ensure that the right of all Americans to express their beliefs in our nation’s capital will be safeguarded.


    American Hiking Society
    American Library Association
    American Public Health Association
    Americans for Financial Reform
    Anti-Defamation League
    Asian American Legal Defense and Education Fund (AALDEF)
    Association of Outdoor Recreation and Education Professionals
    Association of Research Libraries
    Athlete Ally
    The Avarna Group
    Bend the Arc
    Bold Alliance
    Brown Environmentalist
    Brown People Camping
    Californians for Western Wilderness
    Campaign for Accountability
    Catharsis on the Mall
    Chesapeake Climate Action Network
    Church of Scientology National Affairs Office
    Citizen's Climate Lobby
    Coalition for Humane Immigrant Rights (CHIRLA)
    Common Cause
    Council on American-Islamic Relations (CAIR)
    Defend Our Future
    Defending Rights & Dissent
    Democracy for America
    Diverse Environmental Leaders
    Dogwood Alliance
    Earth Ethics
    Earthwise Productions
    Endangered Species Coalition
    Environmental Defense Fund
    Friends of the Earth US
    GLBTQ Legal Advocates & Defenders (GLAD)
    Government Accountability Project
    Green Muslims
    Hip Hop Caucus
    Hispanic Access Foundation
    Hispanic Federation
    Human Rights Campaign
    Human Rights Watch
    Interfaith Power & Light
    Jews United for Justice
    Lambda Legal
    Latino Outdoors
    League of Conservation Voters
    League of Women Voters of the United States
    NARAL Pro-Choice America
    National Black Justice Coalition
    National Center for Lesbian Rights
    National Coalition Against Censorship
    National Council of Jewish Women
    National Employment Law Project
    National Equality Action Team (NEAT)
    National Federation of the Blind
    National Juvenile Justice Network
    National LGBTQ Task Force
    National Resources Defense Council
    National Women's Law Center
    New Mexico Voices for Children
    Next 100 Coalition
    Oil Change International
    Outdoor Muslims
    People For the American Way Foundation
    Planned Parenthood Federation of America
    Praxis Project
    Project On Government Oversight
    Public Citizen
    Services, Immigrant Rights & Education Network (SIREN)
    Sierra Club
    Southern Poverty Law Center
    Transforming Youth Outdoors
    Veterans For Peace
    The Wilderness Society
    Win Without War
    Women's March

    * * * * * END EXCERPT * * * * *
  5. Church of Scientology National Affairs Office joins call to repeal change to the Internal Revenue Code that threatens to tax nonprofit organizations for the cost of parking and transit benefits provided to their employees. Many have referred to this provision as the “parking lot tax”.

    * * * * * BEGIN EXCERPT * * * * *

    We are a group of leaders from diverse faiths representing a broad range of institutions, including houses of worship, primary and secondary education, higher education, and faith-based nonprofit organizations serving communities around the country and around the world.
    We write with serious concerns about how a little-noticed provision in the Tax Cuts and Jobs Act would tax parking and transit benefits provided by nonprofit organizations and churches. Unless repealed, this provision will require tens of thousands of houses of worship to file tax returns for the first time in our nation’s history and will impose a new tax burden on houses of worship and nonprofit organizations.

    This change in Section 512(a)(7) taxes nonprofit organizations – including houses of worship – for the cost of parking and transit benefits provided to employees. This significant change in the treatment of charitable organizations will require many nonprofit organizations to file federal Form 990-T and pay federal taxes on the cost of parking and transit benefits provided to their staff. Not only does this provision impose a new tax on nonprofits, this provision also burdens nonprofits and houses of worship with burdensome accounting and regulatory compliance costs. It is likely that these costs will exceed the tax actually collected from nonprofit organizations.

    Perhaps worst of all, this provision will hopelessly entangle the IRS with houses of worship, simply because these houses of worship allow their clergy to park in their parking lots. For good reasons grounded in the First Amendment, houses of worship are not required to file tax returns each year. This policy allows houses of worship to operate independently from the government and shields houses of worship from government interference and intrusive public inspection into their internal, constitutionally protected operations, as nonprofit tax returns are available to the public.

    Further, it is our understanding that the Joint Committee on Taxation’s score of a full repeal of Section 512(a)(7) (S. 3332 / H.R. 6460) tells the story of the toll this provision will take on the charitable sector: $1.7 billion over 10 years. Whatever purpose Section 512(a)(7) was intended to serve cannot justify extracting $1.7 billion in taxes from nonprofits and houses of worship within just 10 years.

    While the organizations and houses of worship will pay these taxes, it is the people they serve who will ultimately suffer from this massive diversion of funds from civil society to the government. We believe these impacts from Section 512(a)(7) were surely unintended and unanticipated. We therefore call upon you to repeal Section 512(a)(7) through any appropriate legislative package before the end of this calendar year.

    We thank you for your commitment to ensuring that the United States continues to have a thriving and vibrant spectrum of civil society organizations and healthy and independent houses of worship. We look forward to working with you on this needed technical fix to the Tax Cuts and Jobs Act before the end of this year.

    * * * * * END EXCERPT * * * * *





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