Ezel / IRS Rulings / 201035022

CCA addressed self-employment tax treatment of a minister's compensation and parsonage allowance

Number
201035022
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Ministers, Members of Religious Orders, Christian Science Practitioners (Election)
Topics
Other topics
Code sections
§ 107, § 1402, § 6110
Ruling dated
August 11, 2010
Publicly released
September 3, 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

The Office of Chief Counsel advised that if a minister has an exemption effective under IRC § 1402(e), compensation paid for ministerial services is exempt from self-employment tax. The advice states that designating part of that compensation as a parsonage allowance under IRC § 107, and whether the designated amount is ultimately excludable from income, does not affect the section 1402(e) exemption.

Ruling snapshot

  • Question: Does a minister's section 107 parsonage allowance designation affect an effective section 1402(e) exemption from self-employment tax?
  • Outcome: Advice given
  • Key authorities: IRC §§ 107 and 1402(e); IRC § 6110(k)(3) not-precedent notice

Full text (IRS public release)

ID: CCA_2010081111422869 Number: 201035022
Release Date: 9/3/2010
Office: ----------------------------
UILC: 1402.05-00

From: -----------------------
Sent: Wednesday, August 11, 2010 11:43:02 AM
To: --------------------
Cc:
Subject: RE: Question regarding section 1402

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If a minister has an exemption effective under section 1402(e) compensation paid for ministerial services is exempt from self-employment tax. The fact that a portion of this compensation was designated as a parsonage allowance excludable for income tax purposes under section 107, and whether the entire amount designated as such was ultimately excludable from income, would not affect the exemption under section 1402(e).

Let me know if you have further questions.

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