“You never know how much you really believe anything until its truth or falsehood becomes a matter of life and death to you.” –C. S. Lewis
“Truth is ever to be found in simplicity, and not in the multiplicity and confusion of things.” – Isaac Newton
If I asked you, “How do you define what constitutes a church?” what would you say?
According to the Encyclopedia Britannica:
church, in Christian doctrine, the Christian religious community as a whole, or a body or organization of Christian believers.
The Greek word ekklēsia, which came to mean church, was originally applied in the Classical period to an official assembly of citizens. In the Septuagint(Greek) translation of the Old Testament (3rd–2nd century BCE), the term ekklēsia is used for the general assembly of the Jewish people, especially when gathered for a religious purpose such as hearing the Law (e.g., Deuteronomy 9:10, 18:16). In the New Testament it is used of the entire body of believing Christians throughout the world (e.g., Matthew 16:18), of the believers in a particular area (e.g., Acts 5:11), and also of the congregation meeting in a particular house—the “house-church” (e.g., Romans 16:5).
According to the SBC IMB:
A New Testament church is a group of believers in Jesus Christ who assemble together regularly and who are committed to one another to be the body of Christ together.
According to The Gospel Coalition, it must involve, get ready for it, discipline! (Are you shocked? 😉 )
Robert Banks expresses this well in his influential book Paul’s Idea of Community: “The ekklesia is not merely a human association, a gathering of like-minded individuals for a religious purpose, but is a divinely created affair.” Here, then, is a simple definition: The local church is a community gathered around Jesus by his Word. Note that it says “a community,” not “any group.” As mentioned above, the community envisaged in Matthew 18:15–20 is one that gathers repeatedly and exercises formal discipline.
According to Focus on the Family in 2009 (There is a reason I include this, so hold on…)
…every Christian needs to be part of regular fellowship and worship. Edification is also a role of the church. It involves edifying believers, but also nurturing, building up or helping believers to mature in Christ. To this end, churches are tasked with a variety of ministries such as Bible study, continuing education in related areas, praying for one another, acts of genuine hospitality and more. Evangelism is also a key role of the church. This means reaching out to a lost world with the Good News about Jesus. Since people often have questions or doubts about Christ and Christianity, knowing the truth and being able to defend it (apologetics) is also part of the role of the church. But beyond evangelism in the sense of reaching out with the gospel, the church must also express compassion and mercy tangibly by helping others. In following Christ’s example to love others, the church, too, must seek to make a real difference in the world while not neglecting to share the message of Christ. If a church fails to fulfill any of these key roles – worship, edification, evangelism – then the church is not functioning as God intends. Granted, there are times when churches face challenges and struggles to one degree or another, but a healthy church seeks to overcome such challenges in a way that honors God and His intentions for His church.
What are the names of some churches?
- In 2017, Focus on the Family declared itself a church
as did (link)
- The Family Research Council
- The Billy Graham Evangelistic Association.
- Samaritan’s Purse
as well as (link)
- Gideons International
- Voice of the Martyrs
- Ravi Zacharias International Ministries (RZIM) (now defunct)
- most major televangelists
- Liberty Counsel
- the American Family Association
- Ethnos 360/New Tribes Mission
- The Navigators
- World Vision
Huh? Are you naive enough to assume this is just a “hole” in the IRS system? Let’s take a look at this.
What is a church as defined by the IRS? The 14 points test or ‘Churches defined.’
The term church is found, but not specifically defined, in the Internal Revenue Code. With the exception of the special rules for church audits, the use of the term church also includes conventions and associations of churches as well as integrated auxiliaries of a church.
Certain characteristics are generally attributed to churches. These attributes of a church have been developed by the IRS and by court decisions. They include:
- Distinct legal existence
- Recognized creed and form of worship
- Definite and distinct ecclesiastical government
- Formal code of doctrine and discipline
- Distinct religious history
- Membership not associated with any other church or denomination
- Organization of ordained ministers
- Ordained ministers selected after completing prescribed courses of study
- Literature of its own
- Established places of worship
- Regular congregations
- Regular religious services
- Sunday schools for the religious instruction of the young
- Schools for the preparation of its members
The IRS generally uses a combination of these characteristics, together with other facts and circumstances, to determine whether an organization is considered a church for federal tax purposes.
Except, there are exceptions. It appears that the entity does not need to meet all 14 points. According to LegalZoom:
However, in some cases, a religious organization may qualify as a church even if it does not appear to be a church in the traditional sense. This is the case with Young Life, a nonprofit organization that the IRS officially recognized as a church following a July 2005 Ruling.
Interestingly, Young Life does not have an established place of worship or church building per se, but it does have weekly meetings at specific locations. In the end, although Young Life did not meet all federal criteria for religious entities, the IRS concluded that it did meet a sufficient number of them to qualify as a church.
The bottom line is that the IRS has created specific guidelines on churches and other religious entities to determine their tax status. However, it is not a requirement that a church meets all the criteria. Instead, the IRS offers flexibility, allowing various religious institutions to qualify for the highly coveted tax-exempt status.
Why would an organization want to be classified as an IRS-recognized church?
The answer to this question and many questions surrounding “why churches do what they do” is related to keeping stuff about money and politics secret. According to the IRS:
Every organization exempt from federal income tax under Internal Revenue Code section 501(a) must file an annual information return except:
- A church, an interchurch organization of local units of a church, a convention or association of churches
- An integrated auxiliary of a church
- A church-affiliated organization that is exclusively engaged in managing funds or maintaining retirement programs
- A school below college level affiliated with a church or operated by a religious order
- Church-affiliated mission societies if more than half of their activities are conducted in, or are directed at persons in, foreign countries
- An exclusively religious activity of any religious order
Keeping donors, donations, and salaries a secret
Let’s go back to Focus on the Family, which in 2017 declared itself a church. Guess why they did it, and in so doing, negate their definition of the church in 2009. Christian Post wrote in 2018 Focus on the Family Defends IRS Classification as a ‘Church,’ Says It’s Meant to Protect Donors.
The piece noted that the Colorado-based conservative Christian organization has long identified as a non-church 501(c)(3) nonprofit. By 2015 fiscal year, it had been relabeled a “church.”
…Batura explained that the main reason for the reclassification was to protect the identities of donors to the conservative Christian organization.
“In recent years there have been several occasions on which nonprofit organizations were targeted for information, including the names and personal details of their donors. In order to protect our constituents’ privacy, and because Focus does, in fact, meet the definition of a church under IRS regulations, we applied for and received this designation,” said Batura.
…The organization’s board of directors are its ‘elders.’ It’s president, Jim Daly, is its ‘head deacon and elder.’ Listeners to the organization’s radio programs are ‘an extension of its congregation,'” stated the RWW article, which labeled the reclassification as a church “puzzling.”
…”In a hostile environment, we’re going to do everything we can do within the parameters of the law to ensure our freedom to continue to proclaim the Gospel of Jesus Christ, protect and defend the sanctity of life, help couples with their marriages, help parents raise their children, and find forever homes for orphaned children,” said Batura.
Ummm, is this the only reason?
Religion News Services posted an Op-Ed: Religious right groups’ tax-status changes demean both church and state. This was subtitled: “No honest person would call the political organization a church.”
ProPublica, the pro-transparency news nonprofit, reported this week that the FRC and its overtly political arm, FRC Action, no longer have to file Form 990, the standard IRS disclosure that offers basic information about a tax-exempt nonprofit’s key donors, expenditures and staff. It also gives some assurance a group is honoring the limits on political activity Congress has placed on organizations whose donors receive a tax write-off.
Besides “worrying about” key donors and supposedly protecting them, they do not have to disclose expenditures, particularly on staff. In other words, they don’t have to talk about salaries. They also don’t need to divulge if they have gone over the limit of allowable political activity.
This insults real churches.
the FRC’s new designation insults the groups that do conform to the intent of the law. Congregations deserve the social and financial privileges they get. They do the everyday work of building actual religious communities around faith and order, worship and sacraments, and bolstering the social fabric of communities throughout the nation. For these vital social goods, which God alone knows, churches receive special consideration from the IRS.
When even the religion census doesn’t recognize these 990 avoiders
Christianity Today posted When Can a Ministry Count as a Church?
The reclassification might be meaningful for the IRS, but for the Association of Statisticians of American Religious Bodies (ASARB), it doesn’t count. Literally: The Family Research Council (FRC) will not be included in the US religion census, scheduled for publication this fall.
One reason these groups may be concerned about their donors.
In 2016, an executive at the tech company Mozilla was publicly shamed for a donation he made to a political organization opposing same-sex marriage. He was forced to resign, raising concerns among conservative Christian groups that donors could face stiff social consequences for unpopular associations.
“This was done primarily to protect the confidentiality of our donors,” a Focus on the Family spokesman told Ministry Watch in 2020. “In recent years there have been several occasions on which non-profit organizations—on both the right and the left—were targeted for information, including the names and personal details of their donors.”
It appears that the BGEA was concerned about the following information being made available.
The 990 can require disclosure of other information as well. The BGEA’s last 990, covering 2014, included an explanation of the evangelistic association’s policies on first-class airline tickets. It also had information about Billy Graham’s health care costs, the housing provided to longtime music director Cliff Barrows, and an additional $100,000 above base salary paid to Franklin Graham.
… Most, like the BGEA, have voluntarily shared financial information on their websites, but kept some details, such as salaries and compensation packages, private.
Maybe it’s time for donors to reconsider donating to groups that will not disclose salaries and compensation packages paid for by the hard-earned money of the average donor.
I find it disturbing that the BGEA would want to keep the salary and compensation package for Franklin Graham a secret. Graham is estimated to make around $1 million/year. I would not be surprised if this did not include all sorts of other compensation. He does love those black leather jackets.
A final thought
These Christian organizations knowingly lie when they claim to be churches. Keeping Franklin’s salary a secret is far more important than telling the truth. I wonder what else they are lying about. I do not trust the integrity of any of these named organizations and will make sure I no longer donate to those who would lie and say they are churches when they know it’s not true.
Playing IRS games doesn’t look good to the average church attendee who is taught to tell the truth and pay their taxes based on that truth.