I have served as a pastor in different roles, both employee and self employeed. I have served with a denomination, presently in a non-denominational church. I desire to take advantage of the 15 years of service catch up contributions. But I don't have 15 years. Since even a self employeed minister is considered an eligilble participant for a 403(B) it seems there is flexibility when it comes to people in ministry. My questions is this - can I just bunch together all my years in ministry or is there a specifics approach I must follow. Thanks.

The rules require that the eligible employee have 15 yrs of service with the qualified organizaton which includes a church. One question how much service have you had with the church in you now serve? Second q- what is your relationship with the denomination? Third Q how much service do you have with the denominaton? There is an unanswered question as to whether self emplyed ministers can aggregate service when they work for several different churches in the same denominaton. Some tax advisors consider each church to be a separate employer.

Finally, a cite I can even live with...

Check out Rev. Rule 69-629. The determining factor is the 15 YOS must be with the district (or employer) that where the annuity was purchased.

I knew there had to be a definitive answer out there...somewhere.

69 is divine!!

Interesting but not dispositive---or revelant to the question. 69-629 pertains to the exclusion allowance which was repealed last year. The language for the catch up provison in 402(g)(8) is worded differently. If the IRS thought that 69-629 was dispositive it would have cited the ruling in the audit guidelines on how to count 15 years of service instead of the language that implies that in theory the service can be with a different employer.

don't you find it interesting that the FAQs on the IRS's403(B) cite seem to take the same position? Service is dictated for 403(B) services based on the employer who started the annuity. Moving the annuity to another employer appears to be the equivalent to starting the service clock all over again. I think the only way one could consider the church the same employer is if the employee worked for the same diocese, but different churches--so long as the diocese, not the church is the employer. Same with a hospital group...if I work for Shriners, then I can have service with any Shriners hospital. Same with a the XYZ school district--I can work for several schools within the district and count service, but just because I'm eligible to participate in the State's Retirement Plan, I'm not really a State employee. Do you really think the language is meant to be that ambiguous?