Ezel / IRS Rulings / 1109027
Chief Counsel Advice 1109027 Released March 4, 2011 Advice

CCA 1109027: SECA treatment under a totalization agreement falls under IRC § 1402(b)

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This page covers one taxpayer's ruling from 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 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

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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