Church Plan Definition (November 26, 2018)


The Church Alliance submitted a comment letter supplementing the comment letter submitted on August 20, 2018 to the Treasury Department and Internal Revenue Service concerning the definition of a “church plan” in section 414(e) of the Internal Revenue Code.  The supplemental comment letter recommends that proposed Regulations provide that a “convention or association of churches” can be made up of churches from more than one denomination, or even other conventions or associations of churches. The supplemental letter also recommends that the Regulations provide that an organization can be controlled by or associated with an “association of churches” if it is controlled by or associated with two or more churches.