Priorities for IRS Guidance (June 7, 2019)
The Church Alliance submitted a comment letter to the Internal Revenue Service on June 7, 2019 in response to a Request for Comments on the 2019-2020 Priority Guidance Plan (contained in Notice 2019-30). We advised the Service that our top two priorities for further guidance were the Church Plan Definition Regulations and Unrelated Business Taxable Income for disallowed fringe benefits (parking). We noted that we had previously submitted comments on the definition of a church plan on August 20, 2018 and November 26, 2018. Rather than repeat our views and discussion, we provided a link and incorporated our prior comment letters. We urged adoption of the specific recommendations we made in our previous comments and stressed the need for this guidance because the church plan regulations have not been updated since the passage of the Multiemployer Pension Plan Amendments Act of 1980. On the parking issue, we noted and provided a link to the Church Alliance’s previous comments on June 26, 2018 and August 7, 2018. We outlined the need for guidance because the uncertainty in compliance in this unfamiliar territory is adding even more pressure on resources needed for the ministries of Church Alliance members.