Ezel / IRS Rulings / 201020011

CCA 201020011: Counsel directed an inquiry to totalization agreements

Number
201020011
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definitions
Topics
Employment taxes
Code sections
§ 3121, § 6110
Ruling dated
March 25, 2010
Publicly released
May 21, 2010
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

In an internal Chief Counsel email about social security taxes, the sender stated that the United States has totalization agreements with the United Kingdom and Germany. The email explained that these agreements are designed to prevent individuals from paying social security taxes to two nations based on the same employment, and advised the recipient to consult the agreements when answering the underlying question.

Ruling snapshot

  • Question: How should an inquiry about possible social security tax obligations in two countries be analyzed?
  • Outcome: Advice given
  • Key authorities: IRC § 3121; U.S. totalization agreements with the United Kingdom and Germany

Full text (IRS public release)

ID: CCA_2010032513183732 Number: 201020011
Release Date: 5/21/2010
Office: -----------------------------
UILC: 3121.00-00

From: --------------------
Sent: Thursday, March 25, 2010 1:18:43 PM
To: --------------------
Cc: ---------------------------------------
Subject: RE: Counsel assistance Request

Greetings ---------

The United States has totalization agreements with the United Kingdom and Germany. These agreements are designed to prevent individuals from having to pay social security taxes to two different nations based on the same employment. In order to answer this question, you will need to take a look at the totalization agreements. They are available on the Social Security Administration's website.

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