Ezel / Tax Rulings / TX
TX 9201L1151D06 Sales and/or Use Tax (State,Local,MTA) 1992-01-15

Did the 1991 Texas tax change make fraternity and sorority membership fees and dues taxable?

Short answer: No. Although the legislation removed the amusement-service exemption for nonprofit organizations such as country clubs, dues and membership fees paid by members of fraternities, sororities, and similar service organizations remained exempt.

Apply this to your situation

This page answers the general question as of 1992. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1992
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. Letters on STAR can be the basis of a detrimental reliance claim only for the taxpayer to whom the letter was directly issued (see 34 Tex. Admin. Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional about your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page) is the authoritative source for any reliance.

Plain-English summary

The Comptroller said fraternity and sorority membership dues and fees remained exempt from Texas sales tax.

The recent legislation had removed the sales-tax exemption for amusement services provided by some nonprofit organizations, such as country clubs. The letter distinguished fraternities, sororities, and similar service organizations from those recreational organizations.

What this means for you

Fraternities and sororities

The 1991 amusement-service change described in the letter did not make ordinary membership dues taxable for the stated type of service organization.

Accountants and tax professionals

The holding is short and fact-specific. It does not classify separate event, facility, food, or merchandise charges.

Common questions

Were fraternity dues taxable? No.

Were sorority dues treated the same way? Yes.

Did the letter exempt every charge by these organizations? No. It addressed dues and membership fees only.

Citations and references

The letter does not cite a specific statute or administrative rule.

Source

Original ruling text

January 15, 1992

Dear **:

Your letter concerning the taxability of fraternity dues has
been assigned to me for review and response. I appreciate
your patience and apologize for the delay in responding.

The tax bill passed in the recent special legislative session
removed the sales tax exemption for amusement services provided
by nonprofit organizations, such as country clubs.

The dues and membership fees paid by members of fraternities,
sororities, and similar service organizations will continue to
be exempt.

This opinion is based on the facts presented. Other facts
though similar may provide a different result.

If you have other questions or need more information, you may
call 512/463-4600, or 1-800-252-5555 from outside Austin. You
may write to Tax Administration Division.

Sincerely,

Gilbert Zamora
Tax Administration Division

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