IRS PLR: Non-Profit Organization’s Pension Plan Qualifies as Church Plan (IRC §414)

The defined benefit pension plan (“Plan X”) of a tax-exempt organization (“Entity A”) with membership affiliated with “Church” is a church plan within the meaning of tax code Section 414(e), the IRS ruled. Entity A represented that it provides various supportive services to developmentally disabled persons. The IRS concluded that Entity A’s employees are deemed to be employees of a church or a convention or association of churches by virtue of being employees of an organization which is exempt from tax under Section 501 and is controlled by or associated with Church, and that Plan X’s administrative ...