Tax Status of the Regents of the University of California

The Regents of the University of California was formed pursuant to Article IX, Section 9 of the Constitution of the State of California.

The California Secretary of State has recognized the University’s organization under Article IX. While the University is formally organized as a public trust, for ease of reference it is sometimes described as a “public corporation.” It is self-governing, however, and not subject to the California nonprofit public benefit corporation law.  

The University is comprised of ten campuses, six medical centers, the Agricultural and Natural Resources (ANR) System, and the Office of the President, none of which are separate entities for state or federal tax law purposes. The University also manages the operations of or has affiliations with certain other U.S. Department of Energy labs.  

The University's Employer Identification Number (EIN) is 94-3067788. The University is qualified for tax-exemption as an organization described in Section 501(c)(3) of the Internal Revenue Code of 1986, as amended, and is also classified as a public charity under Code Section 509(a)(1).    

To the extent that an agreement is entered into by the University of behalf of a campus, or in the case of a specific grant agreement from a foundation or other funder, to the extent grant funds are designated for use at a specific campus, the language in the agreement typically is stated as “The Regents of the University of California, on behalf of its [Name of Campus] campus. For example, if a foundation is making a grant to the UCSB, the grant agreement would be between [Name of Foundation] and The Regents of the University of California, on behalf of its Santa Barbara campus (“UCSB”). Future references in any such agreement could then be made to UCSB. 

While some University campuses, using campus-specific EINs, have obtained their own IRS determination letters, campuses are not separate corporate entities (PDF). These campus-specific EINs should be valid for purposes of verifying the University’s tax-exempt status; however, any legal agreements should reference EIN 94-3067788.