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Timing of Taxability of Missionary Support Handled by an Agency

Question:

A mission agency inquires as to the amount included on Form 1099-MISC filed each year. The office believes that the should be the total of all of the support that came in for the missionary during the year. Most of its missionaries zero out their accounts each month (i.e., what comes in to the agency's account each month goes out to the missionary immediately).


A missionary asks the agency to deposit a set amount each month into his/her personal account and to leave the rest in the hands of the agency. A clarification is needed as to whether the amount received by the agency or the amount disbursed to the missionary is the proper amount to record on Form 1099-MISC.

Answer:

The answer to this question relates to a tax concept called "constructive receipt." If a mission is simply acting as a clearing house for contributions and missionaries have unlimited and unsupervised access to funds held on their behalf, then all funds are taxable to the missionary as they are received by the mission. In these cases, all contributions received by the missionary are immediately reported as taxable income since he or she had unrestricted access to them. They were constructively received even if not deposited into a personal bank account.

However, to my understanding, most mission agencies take an active role in serving both the donors and the missionaries. Donors understand that such agencies receive contributions on the behalf of their missionaries and provide oversight in disbursements to them. Missionaries must submit budgets for their personal living expenses. They must document business expenses for appropriate reimbursement out of funds received by the agency from donors.

If donors designate contributions to special projects on a missionary's post, then the agency ensures compliance with the designation.

In these cases, a missionary is taxed only as he or she receives funds from the mission for personal living expenses.

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