Ezel / IRS Rulings / 201109027

CCA 201109027: SECA treatment under a totalization agreement falls under IRC § 1402(b)

Number
201109027
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definitions
Topics
Other topics
Code sections
§ 1402, § 6110
Ruling dated
January 31, 2011
Publicly released
March 4, 2011
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 2011, 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 2011
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

Chief Counsel advice agreed that the provision governing self-employment contributions under a totalization agreement is IRC § 1402(b). The one-line email response addressed the treatment of SECA, the Self-Employment Contributions Act, in the context of a nonresident alien question.

Ruling snapshot

  • Question: Which Code provision governs SECA under a totalization agreement?
  • Outcome: Advice given.
  • Key authorities: IRC § 1402(b).

Full text (IRS public release)

ID: CCA_2011013112010641 Number: 201109027
Release Date: 3/4/2011
Office: -----------------------------
UILC: 1402.00-00

From: ---------------
Sent: Monday, January 31, 2011 12:01:08 PM
To: ------------------------------------------
Cc: ------------------
Subject: RE: NRA SE tax

-----------I agree with you. The provision for SECA under a totalization agreement is under section
1402(b).

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