Organizations that do not qualify as a “steeple” employer are permitted to designate a part of a minister’s compensation as housing if the employer is an integral part of a religious organization such as a local church, region or denomination. Criteria for determining whether the employer is an integral part of a religious organization include whether:

  • The religious organization incorporated the institution
  • The corporate name of the institution indicates a church relationship
  • The religious organization continuously controls, manages, and maintains the institution
  • The trustees or directors of the institution are approved by or must be approved by the religious organization or church
  • Annual reports of finances and general operations are required to be made to the religious organization or church
  • Trustees or directors may be removed by the religious organization or church
  • The religious organization or church contributes to the support of the institution
  • In the event of dissolution of the institution, its assets would be turned over to the religious organization or church.

While an institution may not need to meet all of these criteria, a majority probably will have to be satisfied for the organization to be eligible to declare a part of clergy staff compensation as housing allowance.