Untitled Texas Attorney General Opinion

‘%USTXN 11. TEXAS WILL WILSON A’PIORNEYOENERAL December 13, 1962 Honorable Robert S. Calvert Opinion No. WW-1497 Comptroller of Public Accounts Capitol Station Re: Exemption from inheri- Austin, Texas tance tax of a devise and bequest __.. _- to. the . Natlonal r'ounaation for Infantile Paraly- Dear Mr. Calvert: sis, Inc. In Attorney General's Opinion No. NW-1349 the exemption from Inheritance tax of this same devise and bequest was denied. The controlling provisions of the decedent's will are para- graphs IX, X and XI which read as follows: "In the event I shall survive my wife, then I hereby give, devise and bequeath unto my Trustees hereinabove named all my property, both real, per- sonal or mixed, of which I may die seized and possessed, IN TRUST NEYER- THELESS to hold, manage, control, sell and convey the asme In accordance with the authority hereinafter conferred upon them. "The beneficiaries of this trust shall be The American Cancer Society, Texas Division, a non-profit corpora- tion, incorporated under the laws of the State of Texas and the National Foundation for Infantile Paralysis, Inc., a corporation organized under the Membership Corporations Law of the State of New York, having its principal office at 120 Broadway, New York, New York. My estate and the income, rents and revenues there- from, Including the proceeds of the same, shall be used by said corpora- tions for the purposes and uses hereln- after set out. "The term of,thls trust shall be for a period not to exceed five years from and after the date of my death. . . .i Honorable Robert S. Calvert, Page 2 Opinion No. WW-1497 c "During the pendency of this trust, after the payment of all expenses thereof, there shall be paid by my Trustees one-half of the income, rents and revenues from the property of my estate to The American Cancer Society, Texas Division, with its office at Houston, Texas, and one-half of the income, rents and revenues from the property of my estate shall be paid to the National Foundation for In- fantile Paralysis, Inc., a New York corporation. Prior to the termination of this trust, I direct that my Trustees shall sell all of the property of my estate and shall deliver one-half of the proceeds of the same, together with one-half of the net income there- from after the payment of all expenses of administering this trust, to each of the beneficiaries, to be made at the discretion and in the amounts as may be determined by the Trustees. "The American Cancer Society, Texas Division, shall use all of the funds received by it from my Trustees for research in the methods of treatment, diagnosis and prevention of cancer, and to aid in the care of indlgent cancer patients in securing adequate diagnosis and treatment, and any other activities which may contribute to the control of cancer in such man- ner as may be directed by said cor- poration; provided however, that all of the funds which may be received by The American Cancer Society shall be used by it and expended for any and all of said purposes within the State of Texas. "The National Foundation for Infan- tile Paralysis, Inc., shall use such funds as may be received by it for the purposes for which it is incorporated." Article 14.06, Ch. 14, Tit. 122A, 20-A, Tax.-Gen., Vernon's Annotated Texas Statutes, contains the provisions requisite to exemption from inheritance tax. The pertinent portions of Article 14.06 are the following: Honorable Robert S. Calvert, Page 3 Opinion No. WW-1497 "If passing to or for the use of. . .rellglous, educational or charitable organization or insti- tution,. . .the tax shall be: 11. . . "Provided, however, that this Article shall not apply on property passing to or for the use of. . . any religious, educational or charl- table organization Incorporated, unincorporated or in the form of a trust, when such bequest, devise or gift is to be used within this State. "The exemption from tax under the preceding provisions of this Article shall, without limiting Its appllca- tion under other appropriate clrcum- stances, apply to all or so much of any ,bequest,devise or gift to or for the use of. . .a religious, edu- cational or charitable organization, which is, In writing and prior to the payment of the tax, Irrevocably committed for use exclusively within the State of Texas or transferred to a religious, educational or charitable organization for use exclusively wlth- in this State, "Provided, further, that if the property so passing is to or for the use of a religious, educational, or charitable organization which conducts its operations on a regional basis, one such region of which includes the State of Texas, or any part thereof, then a bequest, devise or gift to be used within such region shall be deemed to be used within this state. "For purposes of this paragraph a region shall comprise not more than five contiguous states, either in whole or in part, one of which is the State of Texas." "For purposes of this paragraph, a religious, educational, or charitable Honorable Robert S. Calvert, Page 4 Opinion No. WW-14%' organization shall include, but not be limited to, a youth program of physical fitness, character de- velopment, and citizenship training or like program." At the time Opinion No. WW-1349 was written, the attor- neys representing the estate took the position that the fact that the beneficiary was a charitable corporation was suffi- cient to effectuate exemption, This office rejected this view and denied exemption since the requisite geographical limitations as to use had not been met. Subsequent to the rendition of Opinion No. WW-1349, the National Foundation elected to commit the funds involved for use in a region of five contiguous states composed of Texas, Arkansas, Louisiana, Missouri and Oklahoma. As evi- dence of this commitment, we have been furnished with a letter addressed to the attorneys representing the estate from John J. O'Connor stating that he is enclosing a letter from Mr. Joseph F. Nee, Senior Vice-President of the National Foundation "irrevocably committing all moneys passing to it under the Last Will and~Testament of the. . .decedent for use exclusively within Region 5 of its organizational structure, which Region includes the five contiguous States of Texas, Arkansas, Louisiana, Missouri and Oklahoma." Attached to the letter is a duly certified copy of a resolution of the Board of Trustees of the National Foundation authorizing the officers thereof to make a commitment of this nature. The National Foundation is a corporation duly organized and existing under the laws of the State of New York. The resolu- tion was unanimously adopted by the Board of Trustees of the corporation at a meeting duly called and held on May 14, 1959. The resolution is still in full force and effect. In sub- stance it authorizes the President or Vice-President, together with the Secretary or Treasurer or an Assistant Secretary or an Assistant Treasurer of the National Foundation to accept, assign, exchange, or consent to a reduction in, or modifica- tion of, any share in, or payment, from any estate or other fund if consistent with the purposes of the National Founda- tion, and to agree in their discretion to performance of the National Foundation, or any of its chapters, of any condition or restriction lawfully imposed upon the use of any bequest or devise, and to execute and deliver any consent which the said officers may deem necessary or desirable for the accomp- lishment of any of the powers described in the resolution, and In addition to all powers specifically described in the resolution to do any of the acts which the National Foundation can do through its officers with respect to the estate of a decedent in which the National Foundation or any of its chap- ters has an interest. Honorable Robert S. Calvert, Page 5 Opinion No. WW-1497 We quote the following excerpt from a letter signed by Joseph F. Nee, Senior Vice-President of the National Founda- tion: "In order to avail itself of the exemption from the payment of these Inheritance taxes in the aforemen- tioned amount provided by Article 14.06 of the Vernon's Texas Civil Statutes, The National Foundation hereby irrevocably commits all the monies received by It as a benefi- ciary named In the last Will and Testament of the subject decedent for use exclusively within Region V of its organizational structure, which Region includes the five con- tiguous States of Texas, Arkansas, Louisiana, Missouri and Oklahoma." We will first consider whether the proposed commitment is consistent with the Intention of the decedent as expressed In the provisions creating the testamentary trust. It is true that the decedent saw fit to limit the expenditure of the trust funds bequeathed to the American Cancer Society to use within this State. However, no such limitation, in fact no geographical limitation of any kind, was placed upon the National Foundation except as such geographical limitations might be Imposed by its charter. The law is settled that a will may be construed only In cases in which there Is am- biguity. In those cases in which Intention of the testator is clearly and unequivocally expressed, there is no room for construing a will. 44 Tex.Jur. 677, Wills, Sec. 131. The National Foundation receives the Income from this trust free of any restrlctlon save that previously referred to and could, consistently with this provision of the will, commit the expenditure of the funds as they have attempted to do in this case. Further, In this connection, It Is noteworthy that at the termination of the trust, which may exist for a period of not to exceed five years, the National Poundation will receive its share of the trust corpus and will have full and absolute ownership thereof. We therefore conclude that the attempted commitment is not contrary to the expressed intention of the decedent, and therefore is not in contravention of the terms of the testamentary trust. We pass now to a consideration of the question of whether the commitment, as submitted, meets the requirement of the statute, and is:sufficient to effectuate exemption. Honorable Robert S. Calvert, Page 6 Opinion No. WW-1497 We first call your attention to a matter which could, of course, be easily corrected. The letter committing the fund to use within Region V of the organization of the National Foundation is signed only by the Senior Vice-President.. Under the terms of the resolution pursuant to which the Vice-President is authorized to make such a commitment, he must be joined with the Secretary or the Treasurer, or,an Assistant Secretary or the Assistant Treasurer, of the National Foundation. No facts have been submitted to us as to the manner in which the National Foundation conducts its regional opera- tions in general nor its specific operations in Region V. However, this office on two different occasions has construed the meaning of "regional basis" as that term is used in the statute. We quote the following excerpt from Opinion No. ww-1146: (1 . . .It is clear to us, that for a charitable organization to conduct its operations on a 'regional basls3, as that term is used in the ,statute, that the entire field of its opera- tions would have to be divided into separate and distinct regions and be of a permanent nature, with each re- gion being subject to local manage- ment and control, under proper dlrec- tlves from the officers or directors of the charitable organization." Opinion No. WW-1141 held that it was not essential that a charitable organization be oper,atingon a regional basis at the date of the decedent's death nor that there be more than one reglon in order to be entitled to exemption if such regional operation is effectuated prior to the pay- ment of the tax. The opinion discusses the history of the enlargement of the charitable exemption, but states that the statute necessarily contemplates that the State of Texas receive some benefit before exemption will be allowed. We quote the following excerpt from page 9 of the opinion: 1, .Since we have no fixed legis- lative'standard to use as a guide, we are of the opinion that each particular case must rest upon its own facts, and that if the facts show that this State will receive substantial benefit as a result of the regional operations of the charitable organization, exemption should be accorded." - . Honorable Robert S. Calvert, Page 7 Opinion No. WW-1497 If, therefore, facts are submitted to you which indi- cate (1) that there will be an operation on a "regional basis" in Region V and (2) that Texas will receive substantial bene- fit from such operatlon, exemption from inheritance tax should be accorded. SUMMARY The National Foundation for Infantile Paralysis, Inc. may, consistently with the provisions of a testamentary trust of which it Is a beneficiary, commit the funds it receives therefrom for use within,Region V of its organizational structure, which Re- gion Includes the five'contiguous States of Texas, Arkansas, Louisiana, Missouri and Oklahoma. If facts are submitted to you which indicate (1) that there will be an operation on a "regional basis" In Region V and (2) that Texas will receive sub- stantial benefit from such operation, exemption from Inheritance tax should be accorded. Yours very truly, WILL WILSON Attorney General of Texas APPROVED: OPINION COMMITTEE W. V. Geppert, Chairman Iola Wilcox John Reeves Robert Rowland Bob Shannon REVIEWED FOR THE ATTORNEY GENERAL By: Leonard Passmore