February 06, 2008

Minister's Retirement Distributions Designated as Housing Allowance

There's lots of IRS authority (or precedent) for a local church or a denominational body to designate a minister's retirement benefits as housing allowance:
1. Audit Guide: Ministers: Market Segment Specialization Program
2. Letter Rulings 7734028, 7939077, and 8344062
3. Revenue Rulings 62-117, 63-156, and 75-22

A church is considered to be the sponsor of a 403(b) (Tax Sheltered Annuity) plan that receives the elective deferral withholdings of and matching contributions for its pastor. Accordingly, distributions from these plans qualify for housing allowance designation by the church.

I find no evidence that funds in an IRA account, either originally contributed to it or rolled into it from a 403(b) plan, qualify for housing allowance designation by the church.