Rev. Rul. 74-493

A cooperative hospital service organization described in section 501(e) of the Internal Revenue Code of 1954, employs a number of individuals.

The express intent of section 501(e) of the Code is that an organization described therein shall be treated as if it were an organization described in section 501(c)(3) for all purposes of the Internal Revenue Code.

Held, since services performed in the employ of organizations described in section 501(c)(3) of the Code are excepted from "employment" under section 3121(b)(8)(B) of the Federal Insurance Contributions Act (chapter 21, subtitle C of the Code) and section 3306(c)(8) of the Federal Unemployment Tax Act (chapter 23, subtitle C of the Code) the remuneration paid for such services by the cooperative hospital service organization is not subject to the taxes imposed by those Acts. However, for purposes of the Federal Insurance Contributions Act the exemption may be waived by the organization if it files a certificate (Form SS-15, Certificate Waiving Exemption from Taxes Under the Federal Insurance Contributions Act) as provided in section 3121(k) of the Act.