Ezel / IRS Rulings / 1020011
Chief Counsel Advice 1020011 Released May 21, 2010 Advice

CCA 1020011: Counsel directed an inquiry to totalization agreements

Apply this to your situation

This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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.

--------------------

----------------------------------------------------------------------------

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2010, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.