Ezel / IRS Rulings / 1119031
Chief Counsel Advice 1119031 Released May 13, 2011 Advice

CCA 1119031: the Code includes the Totalization Agreement exception

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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.
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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.

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