May 27, 2009

"Start-up" Missions Support by a Local Church

Question:

After participating as a volunteer for three years, a member of a church congregation entered full-time mission work in a foreign country. She began going for about 3 or 4 months at a time and then returning to the U.S. for a few weeks to a month to visit and raise support. In 2007, she paid her own way. In 2008, she began raising support. Some people gave money directly to her, others gave money to the church for her support. In addition, the church sponsored her for support in 2008. She was not required to report back to the church’s internal mission board under any accountable plan arrangement. What advice can you offer to the members of the church’s mission board to better serve its missionary?

Answer:

The IRS will consider her to have entered the “business” of receiving self-employment income for the performance of religious services—representing donors and other organizations (the church) in providing services to people in a foreign country.

I encourage the mission board to establish a designated fund to manage the collection and disbursement of her support. This provides donors a vehicle for tax-deductible contributions. Generally, gifts given directly to her by individuals will be non-taxable to her and non-deductible by them – they are not considered to be rendered as an exchange of services for compensation.

The missionary will need to file Schedule C and deduct her travel and other business expenses as would any other self-employed person (e.g. she’ll need to keep a mileage log and use the standard auto allowance). Since she is not a minister (as defined by the IRS in Publication 517 and other sources that describe sacerdotal duties, etc.), she will not be eligible for a housing allowance and other ministerial tax provisions. She will need to determine whether she will qualify for the Foreign Earned Income Exclusion.

The local church mission board could opt to recommend employment status with the church. Then, FICA taxes could be withheld and matched (as a non-ministerial employee of a church or Christian organization) and an accountable plan for her employee business expenses could be
established.

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