Ezel / IRS Rulings / 201119031

CCA 201119031: the Code includes the Totalization Agreement exception

Number
201119031
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Relief from Taxes by Certain International Agreements
Topics
Other topics
Code sections
§ 1401
Ruling dated
April 12, 2011
Publicly released
May 13, 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 made a slight modification to an earlier discussion of self-employment tax for a nonresident alien. The modification states that the Internal Revenue Code includes the exception for a Totalization Agreement.

Ruling snapshot

  • Question: Where is the exception for a Totalization Agreement included in the nonresident alien self-employment tax analysis?
  • Outcome: Advice given
  • Key authorities: IRC § 1401.

Full text (IRS public release)

ID: CCA_2011041215041641 Number: 201119031
Release Date: 5/13/2011
Office: -----------------------
UILC: 1401.02-00

From: ---------------
Sent: Tuesday, April 12, 2011 3:04:17 PM
To: -------------------------------------
Cc: ------------------------
Subject: RE: 1040NR Nonresidence alien self-employment tax

-------- one slight modification is that it is the Code that includes the Totalization Agreement exception.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace