diff --git a/data/external/income_resources_ce1/coverage_rules.json b/data/external/income_resources_ce1/coverage_rules.json index fecec536..f68ad8e8 100644 --- a/data/external/income_resources_ce1/coverage_rules.json +++ b/data/external/income_resources_ce1/coverage_rules.json @@ -9497,7 +9497,7 @@ "rare_exclusion": null, "residual_default": { "consequence": "covered", - "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." }, "rule_id": "federal_1968_1972", "trigger_facts": [ @@ -9890,7 +9890,7 @@ "rare_exclusion": null, "residual_default": { "consequence": "covered", - "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." }, "rule_id": "federal_1973_1983", "trigger_facts": [ @@ -10449,7 +10449,7 @@ "rare_exclusion": null, "residual_default": { "consequence": "covered", - "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." }, "rule_id": "federal_1984_1986", "trigger_facts": [ @@ -11206,7 +11206,7 @@ "rare_exclusion": null, "residual_default": { "consequence": "covered", - "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." }, "rule_id": "federal_1987_2026", "trigger_facts": [ @@ -14829,10 +14829,10 @@ { "case_id": "cooperative_521_small_remuneration", "consequence": "open", - "description": "The 1978 row reads former 410(a)(10)'s small-remuneration test as reaching an organization exempt \"under 521\"; for 1968-1977 the 1977 note's parenthesis does not close, so its words do not say which side 521 was on (review r6 M-8: the case leaves the question open rather than choosing the covered residual). The case reads former 410(a)(10)'s amount, remuneration below $50 for a calendar quarter's service: at $50 or more both readings cover the pay, so the case does not reach it (review r7 M-8(a)).", + "description": "From 1978, the small-remuneration test in 3121(a)(16) names an organization exempt \"under section 521\" while the one in 409(a)(14) (409(p) as Pub. L. 95-216 added it) names only one \"exempt from income tax under section 501\", and the 1978 row leaves open whether the test reaches a 521 cooperative; for 1968-1977 the 1977 note's parenthesis does not close, so its words do not say which side 521 was on (review r6 M-8: the case leaves the question open rather than choosing the covered residual). The case reads former 410(a)(10)'s amount, remuneration below $50 for a calendar quarter's service: at $50 or more both readings cover the pay, so the case does not reach it (review r7 M-8(a)).", "open_alternatives": [ { - "description": "Read 521 inside the test, as the 1978 row does: remuneration below the threshold is excluded (covered_above_threshold).", + "description": "Read 521 inside the test, as 3121(a)(16) does from 1978: remuneration below the threshold is excluded (covered_above_threshold).", "name": "inside_small_remuneration_test" }, { @@ -15488,7 +15488,7 @@ } ], "consequence": "covered", - "description": "Before mandatory coverage, service for a 501(c)(3) organization is covered only while an actual or deemed waiver certificate is in effect for it, and under an actual certificate only for employees it reaches; the separate small-remuneration test applies, to it and to service for other organizations exempt under 501(a) or 521.", + "description": "Before mandatory coverage, service for a 501(c)(3) organization is covered only while an actual or deemed waiver certificate is in effect for it, and under an actual certificate only for employees it reaches; the separate small-remuneration test applies, to it and to service for other organizations exempt under 501(a); below $100 a year, the row leaves open whether the test reaches a 401(a) trust or a 521 cooperative.", "effective_end": "1983-12-31", "effective_start": "1978-01-01", "family": "nonprofit_service", @@ -15594,7 +15594,7 @@ "amount_cents": 10000, "comparison": "at_least", "concept": "remuneration for service to qualifying 501(a)/521 organization, excluding 401(a) trusts", - "source": "409(a)(14), originally 409(p); Public Law 95-216 section 351 after 1977." + "source": "3121(a)(16) and 409(a)(14), originally 409(p); Public Law 95-216 sections 351 and 356 after 1977." }, "threshold_id": "nonprofit_remuneration_year", "threshold_source_disagreement_resolution": { @@ -15635,7 +15635,7 @@ "rare_exclusion": null, "residual_default": { "consequence": "covered", - "description": "No case holds, so the employer is neither an organization described in 501(c)(3) and exempt under 501(a) nor another organization exempt under 501(a) (other than one described in 401(a)) or under 521: former 410(a)(8)(B) does not exclude the service and 3121(a)(16)'s $100 test does not reach it; apply the other families. A 401(a) trust's or 521 cooperative's employee paid $100 or more in the year also lands here: both readings of the open cases cover that pay." + "description": "No case holds, so the employer is neither an organization described in 501(c)(3) and exempt under 501(a) nor another organization exempt under 501(a) (other than one described in 401(a)) or under 521: former 410(a)(8)(B) does not exclude the service and 3121(a)(16)'s $100 test does not reach it; apply the other families. A 401(a) trust's employee paid $100 or more in the year also lands here, and a 521 cooperative's takes exempt_organization_small_remuneration: both readings of the open cases cover that pay." }, "rule_id": "nonprofit_1978_1983", "trigger_facts": [ @@ -32358,7 +32358,7 @@ "authority": "42 USC 410, current code and amendment/effective-date notes captured 2026-10-21", "capture": "lii_42_410.html", "location": "Effective Date of 1983 Amendment, section 321(b)", - "quote": "Amendment by section 321(b) of Pub. L. 98\u201321 applicable to agreements entered into after Apr. 20, 1983", + "quote": "Amendment by section 321(b) of Pub. L. 98\u201321 applicable to agreements entered into after Apr. 20, 1983 , except that at the election of any American employer such amendment shall also apply to any agreement entered into on or before Apr. 20, 1983 , see section 321(f) of Pub. L. 98\u201321", "sha256": "661681512a6ff124d0af432c54a0f6f1b90b66f956534086c841dc6b8e934e32" }, { @@ -32383,7 +32383,7 @@ "sha256": "579b14057519ec25f74a6bba5feab6274354122085093c4fe950061a9079d52c" } ], - "gap": "No family in this registry reads 410(a)'s base definition of employment. Within the United States, service is employment \"irrespective of the citizenship or residence of either\" (clause (A)(i)). Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). So a case or residual that reads covered does not reach service outside the United States that none of (A)(ii), (B) and (C) reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates; and a citizen's or resident's service abroad for an employer that is neither an American employer nor a foreign affiliate under a 3121(l) agreement in effect, unless a section 433 agreement designates it. That holds for a Federal employer as for any other: POMS RS 01901.340 A names \"services performed outside the U.S. by an alien\" as excluded by some other provision of law (review r6 M-5, r7 H-2 and low 9).", + "gap": "No family in this registry reads 410(a)'s base definition of employment. Within the United States, service is employment \"irrespective of the citizenship or residence of either\" (clause (A)(i)). Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). So a case or residual that reads covered does not reach service outside the United States that none of (A)(ii), (B) and (C) reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates; and a citizen's or resident's service abroad for an employer that is neither an American employer nor a foreign affiliate under a 3121(l) agreement in effect, unless a section 433 agreement designates it. That holds for a Federal employer as for any other: POMS RS 01901.340 A names \"services performed outside the U.S. by an alien\" as excluded by some other provision of law (review r6 M-5, r7 H-2 and low 9).", "provision": "42 U.S.C. 410(a), preamble, clauses (A), (B) and (C)" } ], diff --git a/data/external/income_resources_ce1/government_rules.json b/data/external/income_resources_ce1/government_rules.json index a7150368..b0b52a96 100644 --- a/data/external/income_resources_ce1/government_rules.json +++ b/data/external/income_resources_ce1/government_rules.json @@ -3670,7 +3670,7 @@ "open_alternatives": [], "residual_default": { "consequence": "covered", - "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." } }, { @@ -4063,7 +4063,7 @@ "open_alternatives": [], "residual_default": { "consequence": "covered", - "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when none of the stated statutory exclusion cases applies; apply the other families. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." } }, { @@ -4622,7 +4622,7 @@ "open_alternatives": [], "residual_default": { "consequence": "covered", - "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." } }, { @@ -5379,7 +5379,7 @@ "open_alternatives": [], "residual_default": { "consequence": "covered", - "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." + "description": "Federal service is covered when no case matches; the cases apply in precedence order, first match wins. This family does not read 410(a)'s base definition. Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). No family in this registry reads these conditions, so neither this residual nor a covered case of this family reaches service abroad that none of them reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates (registry scope_gaps, review r6 M-5 and r7 H-2)." } }, { @@ -5839,12 +5839,12 @@ "amount": "remuneration for service performed in a calendar quarter in the organization's employ less than $50" }, "consequence": "open", - "description": "The 1978 row reads former 410(a)(10)'s small-remuneration test as reaching an organization exempt \"under 521\"; for 1968-1977 the 1977 note's parenthesis does not close, so its words do not say which side 521 was on (review r6 M-8: the case leaves the question open rather than choosing the covered residual). The case reads former 410(a)(10)'s amount, remuneration below $50 for a calendar quarter's service: at $50 or more both readings cover the pay, so the case does not reach it (review r7 M-8(a)).", + "description": "From 1978, the small-remuneration test in 3121(a)(16) names an organization exempt \"under section 521\" while the one in 409(a)(14) (409(p) as Pub. L. 95-216 added it) names only one \"exempt from income tax under section 501\", and the 1978 row leaves open whether the test reaches a 521 cooperative; for 1968-1977 the 1977 note's parenthesis does not close, so its words do not say which side 521 was on (review r6 M-8: the case leaves the question open rather than choosing the covered residual). The case reads former 410(a)(10)'s amount, remuneration below $50 for a calendar quarter's service: at $50 or more both readings cover the pay, so the case does not reach it (review r7 M-8(a)).", "open_reason": "COOPERATIVE_521_SMALL_REMUNERATION_UNSETTLED: no CE1 capture prints former 410(a)(10) as in force in 1968-1977, and the 1977 amendment note that records the 521 wording does not close its parenthesis, so whether a 521 farmers' cooperative's employees fell under the small-remuneration test before 1978 is not settled; the case refuses.", "open_alternatives": [ { "name": "inside_small_remuneration_test", - "description": "Read 521 inside the test, as the 1978 row does: remuneration below the threshold is excluded (covered_above_threshold)." + "description": "Read 521 inside the test, as 3121(a)(16) does from 1978: remuneration below the threshold is excluded (covered_above_threshold)." }, { "name": "outside_small_remuneration_test", @@ -6054,7 +6054,7 @@ ], "consequence": "covered", "identification_class": "awaiting_ce2", - "description": "Before mandatory coverage, service for a 501(c)(3) organization is covered only while an actual or deemed waiver certificate is in effect for it, and under an actual certificate only for employees it reaches; the separate small-remuneration test applies, to it and to service for other organizations exempt under 501(a) or 521.", + "description": "Before mandatory coverage, service for a 501(c)(3) organization is covered only while an actual or deemed waiver certificate is in effect for it, and under an actual certificate only for employees it reaches; the separate small-remuneration test applies, to it and to service for other organizations exempt under 501(a); below $100 a year, the row leaves open whether the test reaches a 401(a) trust or a 521 cooperative.", "parameters": { "waiver_effective_date_options": [ "quarter of filing", @@ -6079,7 +6079,7 @@ "comparison": "at_least", "aggregation_unit": "same_employer_employee_calendar_year", "concept": "remuneration for service to qualifying 501(a)/521 organization, excluding 401(a) trusts", - "source": "409(a)(14), originally 409(p); Public Law 95-216 section 351 after 1977." + "source": "3121(a)(16) and 409(a)(14), originally 409(p); Public Law 95-216 sections 351 and 356 after 1977." }, "threshold_id": "nonprofit_remuneration_year", "named_options": [ @@ -6331,7 +6331,7 @@ "open_alternatives": [], "residual_default": { "consequence": "covered", - "description": "No case holds, so the employer is neither an organization described in 501(c)(3) and exempt under 501(a) nor another organization exempt under 501(a) (other than one described in 401(a)) or under 521: former 410(a)(8)(B) does not exclude the service and 3121(a)(16)'s $100 test does not reach it; apply the other families. A 401(a) trust's or 521 cooperative's employee paid $100 or more in the year also lands here: both readings of the open cases cover that pay." + "description": "No case holds, so the employer is neither an organization described in 501(c)(3) and exempt under 501(a) nor another organization exempt under 501(a) (other than one described in 401(a)) or under 521: former 410(a)(8)(B) does not exclude the service and 3121(a)(16)'s $100 test does not reach it; apply the other families. A 401(a) trust's employee paid $100 or more in the year also lands here, and a 521 cooperative's takes exempt_organization_small_remuneration: both readings of the open cases cover that pay." } }, { diff --git a/data/external/income_resources_ce1/scope_gaps.json b/data/external/income_resources_ce1/scope_gaps.json index a46cbec9..954bcfac 100644 --- a/data/external/income_resources_ce1/scope_gaps.json +++ b/data/external/income_resources_ce1/scope_gaps.json @@ -1,7 +1,7 @@ [ { "provision": "42 U.S.C. 410(a), preamble, clauses (A), (B) and (C)", - "gap": "No family in this registry reads 410(a)'s base definition of employment. Within the United States, service is employment \"irrespective of the citizenship or residence of either\" (clause (A)(i)). Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). So a case or residual that reads covered does not reach service outside the United States that none of (A)(ii), (B) and (C) reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates; and a citizen's or resident's service abroad for an employer that is neither an American employer nor a foreign affiliate under a 3121(l) agreement in effect, unless a section 433 agreement designates it. That holds for a Federal employer as for any other: POMS RS 01901.340 A names \"services performed outside the U.S. by an alien\" as excluded by some other provision of law (review r6 M-5, r7 H-2 and low 9).", + "gap": "No family in this registry reads 410(a)'s base definition of employment. Within the United States, service is employment \"irrespective of the citizenship or residence of either\" (clause (A)(i)). Outside the United States, 410(a) makes service employment only (A)(ii) on or in connection with an American vessel or American aircraft under a contract of service entered into within the United States, or one during which the craft touches at a United States port, while the employee is employed on and in connection with it, \"irrespective of the citizenship or residence of either\"; (B) \"by a citizen or resident of the United States\" (before 1984, \"a citizen of the United States\": Pub. L. 98-21 section 323(a)(2), for remuneration paid after 1983) as an employee (i) of an American employer or (ii) of a foreign affiliate of an American employer \"during any period for which there is in effect an agreement, entered into pursuant to section 3121(l)\" with respect to the affiliate (Pub. L. 98-21 section 321(b), for agreements entered into after April 20, 1983, or for an earlier agreement whose American employer elects the amendment under section 321(f), wrote \"American employer\" for \"a domestic corporation\" and \"affiliate\" for \"subsidiary\"); or (C) \"regardless of where or by whom performed\", where an agreement under section 433 designates the service as employment or recognizes it as equivalent to employment (added by Pub. L. 98-21 section 322(a)(1), effective in taxable years beginning on or after April 20, 1983). So a case or residual that reads covered does not reach service outside the United States that none of (A)(ii), (B) and (C) reaches: a noncitizen's before 1984, and a nonresident noncitizen's from 1984, that is not on or in connection with an American vessel or aircraft as (A)(ii) states and that no section 433 agreement designates; and a citizen's or resident's service abroad for an employer that is neither an American employer nor a foreign affiliate under a 3121(l) agreement in effect, unless a section 433 agreement designates it. That holds for a Federal employer as for any other: POMS RS 01901.340 A names \"services performed outside the U.S. by an alien\" as excluded by some other provision of law (review r6 M-5, r7 H-2 and low 9).", "citations": [ { "capture": "lii_42_410.html", @@ -50,7 +50,7 @@ "sha256": "661681512a6ff124d0af432c54a0f6f1b90b66f956534086c841dc6b8e934e32", "authority": "42 USC 410, current code and amendment/effective-date notes captured 2026-10-21", "location": "Effective Date of 1983 Amendment, section 321(b)", - "quote": "Amendment by section 321(b) of Pub. L. 98–21 applicable to agreements entered into after Apr. 20, 1983" + "quote": "Amendment by section 321(b) of Pub. L. 98–21 applicable to agreements entered into after Apr. 20, 1983 , except that at the election of any American employer such amendment shall also apply to any agreement entered into on or before Apr. 20, 1983 , see section 321(f) of Pub. L. 98–21" }, { "capture": "lii_42_410.html", diff --git a/docs/design/income_and_resources.md b/docs/design/income_and_resources.md index c8a3ab19..02a556df 100644 --- a/docs/design/income_and_resources.md +++ b/docs/design/income_and_resources.md @@ -404,7 +404,7 @@ This lane edits nothing under `src/populace_dynamics/track_b/`. It hands outputs - **J, joint validation.** J tests "joint earnings–claiming–DI states, payment and recipient denominators, and survivor pathways" on estimands frozen at B0.2 and ratified before B3 registers (Track B §3.4, §5.2). On current schedules SSI-G and SSI9 cannot pass before J's record is ratified (B3's window is 14 December to 17 January; `parity-forecast-20261021.md:65`), so J excludes SSI. C1's arm (b), C2 and C3 list SSI-inclusive cells in their B7 scope matrix as unsupported unless a separately registered joint Social Security–SSI gate passes. - **B7.** Track B's scope matrix requires each target's "required non-Social-Security income" (§3.4). A B7 target that needs pensions, asset income or SSI is blocked until WP-G and SSI-G pass, until SSI9 for actual SSI receipt, until SSI7 for SSI under 65, and, for joint Social Security–SSI cells, until a joint gate passes (see J). - **B4.** SSI7 needs B4's DI outcomes. WP's widowhood rule uses B4's endogenous widowhood once admitted; before that, WP-G runs on realized support. -- **B0.2.** IR0 reuses B0.2's protocol and record format (PR #554) if B0.2's is frozen. Whether IR0's records sit inside B0.2's or beside it is the coordinator's call. +- **B0.2.** IR0 reuses the protocol and record format of B0.2's version 1, frozen on 2026-10-27 (`docs/design/track_b_b0_2_protocol.md`, #584). Whether IR0's records sit inside B0.2's or beside it is the coordinator's call. - **Insured status.** SSI7 uses the rules lane's insured-status rule, which starts after #530 merges (`parity-forecast-20261021.md:49`). ### 8.2 PolicyEngine-US, policyengine.py and Axiom diff --git a/tests/income_resources/ce1_invented_sweep_workers.json b/tests/income_resources/ce1_invented_sweep_workers.json index e0389b60..2c610ee3 100644 --- a/tests/income_resources/ce1_invented_sweep_workers.json +++ b/tests/income_resources/ce1_invented_sweep_workers.json @@ -5365,7 +5365,7 @@ }, { "rule_id": "state_local_1968_1983", - "worker": "INVENTED: District of Columbia government clerk covered by the Civil Service Retirement System, 1975. 410(a)(7) excludes him (410(h) makes D.C. a State; 410(a)(7)(D) lifts the exclusion only for service not covered by a U.S. retirement system), but the family's scope sends D.C. to state_local_territories_history_open, which refuses. This row's residual says covered and 'so 410(a)(7) does not exclude it', which is wrong for him (NOTE, scope carve).", + "worker": "INVENTED: District of Columbia government clerk covered by the Civil Service Retirement System, 1975. 410(a)(7) excludes this clerk (410(h) makes D.C. a State; 410(a)(7)(D) lifts the exclusion only for service not covered by a U.S. retirement system), but the family's scope sends D.C. to state_local_territories_history_open, which refuses. This row's residual says 'so this family's cases do not exclude it' and leaves a District clerk under the Civil Service Retirement System to other families.", "facts": { "section_218_position": "not covered" }, @@ -6817,7 +6817,7 @@ }, { "rule_id": "nonprofit_1968_1977", - "worker": "INVENTED: Ed, hired 1960 by a 501(c)(3) hospital whose certificate was filed 1968 Q1; he did not sign the Form SS-15a. The hospital filed a supplemental list naming him in 1971 Q2, more than 24 months after 1968 Q1, so not a permitted amendment (1958 (k)(1) note; C.6 NOTE). Service 1972. The law leaves him excluded; the case-1 text, which states no 24-month limit, covers him, and the nonconcurring text is false because a list names him.", + "worker": "INVENTED: Ed, hired 1960 by a 501(c)(3) hospital whose certificate was filed 1968 Q1; he did not sign the Form SS-15a. The hospital filed a supplemental list naming him in 1971 Q2, more than 24 months after 1968 Q1, so not a permitted amendment (1958 (k)(1) note; C.6 NOTE). Service 1972. The law leaves him excluded. The list came after the twenty-fourth month, so the registry decides waiver_nonconcurring_existing_employee, which excludes the service.", "facts": { "nonprofit_organization": "employer is an organization described in 501(c)(3) and exempt under 501(a), whose service former 410(a)(8)(B) excluded", "nonprofit_coverage_waiver": "actual waiver certificate (Form SS-15) in effect for the service: the service falls on or after the certificate's effective date (RS 01901.540 C.3) and before any termination took effect (C.5), and the certificate covers the employee's group where the organization divided its employees under 3121(k)(1)(E)", @@ -6828,7 +6828,7 @@ }, { "rule_id": "nonprofit_1968_1977", - "worker": "INVENTED: Flo, hired 1970-03 by a 501(c)(3) agency whose certificate was filed 1974-08-20 (Q3) effective 1972-01-01; she left 1973-12-31, before the filing, so she could not sign. The agency paid FICA taxes on her 1972-1973 pay before the due date of its 1974 Q2 return; she filed a section 105(b) request in 1976. Pub. L. 86-778 section 105(b) (as amended 1965) deems that remuneration wages; case 6 calls her excluded on every source. M-6.", + "worker": "INVENTED: Flo, hired 1970-03 by a 501(c)(3) agency whose certificate was filed 1974-08-20 (Q3) effective 1972-01-01; she left 1973-12-31, before the filing, so she could not sign. The agency paid FICA taxes on her 1972-1973 pay before the due date of its 1974 Q2 return; she filed a section 105(b) request in 1976. Pub. L. 86-778 section 105(b) (as amended 1965) deems that remuneration wages; the registry decides section_105b_departed_employee_request, which covers the pay above the threshold.", "facts": { "nonprofit_organization": "employer is an organization described in 501(c)(3) and exempt under 501(a), whose service former 410(a)(8)(B) excluded", "nonprofit_coverage_waiver": "actual waiver certificate (Form SS-15) in effect for the service: the service falls on or after the certificate's effective date (RS 01901.540 C.3) and before any termination took effect (C.5), and the certificate covers the employee's group where the organization divided its employees under 3121(k)(1)(E)", @@ -6843,7 +6843,7 @@ }, { "rule_id": "nonprofit_1968_1977", - "worker": "INVENTED: Gil, hired 1972-06 by Flo's agency (after the 1972-01-01 effective date), left 1973-12-31 before the 1974-08-20 filing; taxes paid on time; 105(b) request in 1976. Covered on either reading of the open case (C.4 covers him; on the request-date reading 105(b) does). The registry refuses. M-6.", + "worker": "INVENTED: Gil, hired 1972-06 by Flo's agency (after the 1972-01-01 effective date), left 1973-12-31 before the 1974-08-20 filing; taxes paid on time; 105(b) request in 1976. Covered on either reading of waiver_retroactive_period_hire_unlisted (C.4 covers Gil; on the request-date reading 105(b) does). The registry decides section_105b_departed_employee_request, which covers the pay above the threshold.", "facts": { "nonprofit_organization": "employer is an organization described in 501(c)(3) and exempt under 501(a), whose service former 410(a)(8)(B) excluded", "nonprofit_coverage_waiver": "actual waiver certificate (Form SS-15) in effect for the service: the service falls on or after the certificate's effective date (RS 01901.540 C.3) and before any termination took effect (C.5), and the certificate covers the employee's group where the organization divided its employees under 3121(k)(1)(E)", @@ -7030,7 +7030,7 @@ }, { "rule_id": "nonprofit_1978_1983", - "worker": "INVENTED: Xia, hired 1975 by a 501(c)(3) hospital whose certificate was filed 1978 Q1; not on the Form SS-15a; named on a supplemental list filed 1981 Q1, after the 24th month following 1978 Q1. Service 1982. Law: excluded; registry: case 1.", + "worker": "INVENTED: Xia, hired 1975 by a 501(c)(3) hospital whose certificate was filed 1978 Q1; not on the Form SS-15a; named on a supplemental list filed 1981 Q1, after the 24th month following 1978 Q1. Service 1982. Law: excluded; the registry decides waiver_nonconcurring_existing_employee, which excludes the service.", "facts": { "nonprofit_organization": "employer is an organization described in 501(c)(3) and exempt under 501(a), whose service former 410(a)(8)(B) excluded", "nonprofit_coverage_waiver": "actual waiver certificate (Form SS-15) in effect for the service: the service falls on or after the certificate's effective date (RS 01901.540 C.3) and before any termination took effect (C.5), and the certificate covers the employee's group where the organization divided its employees under 3121(k)(1)(E)", @@ -7041,7 +7041,7 @@ }, { "rule_id": "nonprofit_1978_1983", - "worker": "INVENTED: Yuri, hired 1978 by a 501(c)(3) agency whose certificate was filed 1983-02-15 effective 1980-01-01; he left 1982-06-30, before the filing. The agency paid FICA taxes on his 1980-1982 pay on time; he filed a section 105(b) request in 1983-09. The row has no historical_fica_treatment fact. M-6.", + "worker": "INVENTED: Yuri, hired 1978 by a 501(c)(3) agency whose certificate was filed 1983-02-15 effective 1980-01-01; he left 1982-06-30, before the filing. The agency paid FICA taxes on his 1980-1982 pay on time; he filed a section 105(b) request in 1983-09. The registry decides section_105b_departed_employee_request, which covers the pay above the threshold.", "facts": { "nonprofit_organization": "employer is an organization described in 501(c)(3) and exempt under 501(a), whose service former 410(a)(8)(B) excluded", "nonprofit_coverage_waiver": "actual waiver certificate (Form SS-15) in effect for the service: the service falls on or after the certificate's effective date (RS 01901.540 C.3) and before any termination took effect (C.5), and the certificate covers the employee's group where the organization divided its employees under 3121(k)(1)(E)", @@ -7338,7 +7338,7 @@ }, { "rule_id": "electing_church_1984_1985", - "worker": "INVENTED: Xena, lay organist at a church that existed on 9/30/84 but filed its Form 8274 only in 1985-03, after the 3121(w)(2) deadline (RS 01901.660 A.2: by 10/31/84), so no valid election is in effect. 1985. Law: not 410(a)(8)(B) service. The case text 'electing church' does not state that the election must be valid and in effect for the service.", + "worker": "INVENTED: Xena, lay organist at a church that existed on 9/30/84 but filed its Form 8274 only in 1985-03, after the 3121(w)(2) deadline (RS 01901.660 A.2: by 10/31/84), so no valid election is in effect. 1985. Law: not 410(a)(8)(B) service. The case text requires an election in effect for the service and made in time, so the residual decides.", "facts": { "church_employee_service": "service for a church that filed its Form 8274 after the 3121(w)(2) deadline, so no election is in effect", "taxable_year_start": "1985-01-01" @@ -7408,7 +7408,7 @@ }, { "rule_id": "electing_church_1986_2026", - "worker": "INVENTED: Eben, lay secretary of a church whose 1984 election the Secretary revoked in 1997 under 3121(w)(2) for failure to furnish 6051 information for 1995 and 1996; the revocation applies retroactively to 1995-01-01. Service 1995, when the church was operating as an electing church. Law: no election in effect for the service, so not 410(a)(8)(B) service. The case text 'electing church' does not carry 'has in effect' or the retroactive revocation.", + "worker": "INVENTED: Eben, lay secretary of a church whose 1984 election the Secretary revoked in 1997 under 3121(w)(2) for failure to furnish 6051 information for 1995 and 1996; the revocation applies retroactively to 1995-01-01. Service 1995, when the church was operating as an electing church. Law: no election in effect for the service, so not 410(a)(8)(B) service. The case text requires an election not revoked for the service's period, so the residual decides.", "facts": { "church_employee_service": "service for a church whose 3121(w) election the Secretary revoked under 3121(w)(2), retroactively to the beginning of a 2-year period that includes the service", "taxable_year_start": "1995-01-01" @@ -10347,7 +10347,7 @@ }, { "rule_id": "family_service_1968", - "worker": "INVENTED: Ada, hired in 1980 by a partnership whose only partners are her son and her daughter to keep a lake cottage the partners hold for their own use, not in the partnership's business. POMS RS 01901.250 E applies the family exclusion where it applies \"because of the relationship of the employee to each partner\". She states the parent text (employment by her son and daughter jointly); the text, unlike the child and spouse texts, does not say so (NOTE).", + "worker": "INVENTED: Ada, hired in 1980 by a partnership whose only partners are her son and her daughter to keep a lake cottage the partners hold for their own use, not in the partnership's business. POMS RS 01901.250 E applies the family exclusion where it applies \"because of the relationship of the employee to each partner\". She states the parent text (employment by her son and daughter jointly); the text, unlike the child and spouse texts, does not say so.", "facts": { "family_service": "parent employed by a son or daughter in service not in the course of the employer's trade or business, or in domestic service in the employer's private home; this includes a stepparent employed by a stepson or stepdaughter in such service, also after the natural parent's death, and an adoptive or foster parent employed by an adopted or foster son or daughter in such service", "incorporation": "partnership of the employee's son and daughter" @@ -10539,7 +10539,7 @@ }, { "rule_id": "family_service_1988", - "worker": "INVENTED: Kira, hired in 2016 by a partnership whose only partners are her two daughters to keep a cottage the partners hold for their own use, not in the partnership's business (POMS RS 01901.250 E). She states the parent text (employment by her daughters jointly); the text does not say so (NOTE).", + "worker": "INVENTED: Kira, hired in 2016 by a partnership whose only partners are her two daughters to keep a cottage the partners hold for their own use, not in the partnership's business (POMS RS 01901.250 E). She states the parent text (employment by her daughters jointly); the text does not say so.", "facts": { "family_service": "parent employed by a son or daughter in service not in the course of the employer's trade or business, or in domestic service in the employer's private home; this includes a stepparent employed by a stepson or stepdaughter in such service, also after the natural parent's death, and an adoptive or foster parent employed by an adopted or foster son or daughter in such service", "incorporation": "partnership of the employee's two daughters" @@ -11769,7 +11769,7 @@ }, { "rule_id": "nonresident_alien_service_1968", - "worker": "INVENTED: F-1 student, nonresident alien, granted DHS economic-hardship employment authorization in 2010 and working off campus at a grocery store. POMS C.1.a lists hardship employment among the DHS-authorized work and says authorized F-1 work is not covered, so the admission-purpose text is true of it. Excluded (see NOTE N-FJ-1 on wording).", + "worker": "INVENTED: F-1 student, nonresident alien, granted DHS economic-hardship employment authorization in 2010 and working off campus at a grocery store. POMS C.1.a lists hardship employment among the DHS-authorized work and says authorized F-1 work is not covered, so the admission-purpose text is true of it. Excluded.", "facts": { "nonresident_alien_status": "nonresident alien", "statutory_student_service": "authorized service performed to carry out the purpose of the F or J admission", @@ -12089,7 +12089,7 @@ }, { "rule_id": "statutory_homeworker_service_1968", - "worker": "INVENTED: JUST MISSES (410(j)(3)(C) materials): home seamstress in 1972 who buys her own fabric and sells finished dresses made to a boutique's specifications; the goods are not furnished by the boutique and returned, so she is not in the (C) group. Deferred (see NOTE N-HW-1).", + "worker": "INVENTED: JUST MISSES (410(j)(3)(C) materials): home seamstress in 1972 who buys her own fabric and sells finished dresses made to a boutique's specifications; the goods are not furnished by the boutique and returned, so she is not in the (C) group. Deferred.", "facts": {}, "expected": "deferred", "decides": "residual", @@ -12147,7 +12147,7 @@ }, { "rule_id": "statutory_homeworker_service_1978", - "worker": "INVENTED: JUST MISSES (410(j)(3)(C) materials): home seamstress in 1995 who buys her own fabric and sells finished dresses made to a boutique's specifications; the goods are not furnished by the boutique and returned, so she is not in the (C) group. Deferred (see NOTE N-HW-1).", + "worker": "INVENTED: JUST MISSES (410(j)(3)(C) materials): home seamstress in 1995 who buys her own fabric and sells finished dresses made to a boutique's specifications; the goods are not furnished by the boutique and returned, so she is not in the (C) group. Deferred.", "facts": {}, "expected": "deferred", "decides": "residual", @@ -12223,7 +12223,7 @@ }, { "rule_id": "student_nurse_service_1968", - "worker": "INVENTED: JUST MISSES (capacity): nursing student in an approved school who works weekends in 2018 as a hospital admissions clerk, not as a student nurse; 410(a)(13) reaches 'Service performed as a student nurse'. Occupation text false; covered (see NOTE N-SN-1).", + "worker": "INVENTED: JUST MISSES (capacity): nursing student in an approved school who works weekends in 2018 as a hospital admissions clerk, not as a student nurse; 410(a)(13) reaches 'Service performed as a student nurse'. Occupation text false; covered.", "facts": { "employer_school_nexus": "nurses' training school chartered or approved under State law", "enrollment": "enrolled and regularly attending classes in a nurses' training school" @@ -12377,7 +12377,7 @@ }, { "rule_id": "student_service_1973", - "worker": "INVENTED: JUST MISSES case 3 by date (registry ruling): full-time undergraduate with a long-term part-time job that makes her eligible for the university's retirement plan (fails C.2.b), working on August 14, 2024. The registry does not project C.2 before 2024-08-15 (current_poms_student_criteria.date_axis), so the statutory case excludes; see NOTE N-ST-2.", + "worker": "INVENTED: JUST MISSES case 3 by date (registry ruling): full-time undergraduate with a long-term part-time job that makes her eligible for the university's retirement plan (fails C.2.b), working on August 14, 2024. The registry does not project C.2 before 2024-08-15 (current_poms_student_criteria.date_axis), so the statutory case excludes.", "facts": { "employer_school_nexus": "employer is the school, college or university where the student is enrolled, or a 509(a)(3) organization that is organized, and at all times thereafter is operated, exclusively for the benefit of, to perform the functions of, or to carry out the purposes of it, and is operated, supervised or controlled by or in connection with it", "enrollment": "enrolled and regularly attending classes", @@ -13556,7 +13556,7 @@ }, { "rule_id": "se_material_participation_1974_2026", - "worker": "INVENTED: Len, calendar 1996, investment farm tract, rent received in June 1996, after 1996-04-01; no participation. His taxable year began 1996-01-01, before 1996-04-01, so this family's open case still holds and the row refuses, while se_rental_income_1996_2026 (split by date, not taxable year) treats a June 1996 rental as settled (NOTE).", + "worker": "INVENTED: Len, calendar 1996, investment farm tract, rent received in June 1996, after 1996-04-01; no participation. His taxable year began 1996-01-01, before 1996-04-01, so this family's open case still holds and the row refuses, while se_rental_income_1996_2026 (split by date, not taxable year) treats a June 1996 rental as settled.", "facts": { "real_estate_dealer_status": "rentals a real estate dealer receives from real estate the dealer holds for investment or speculation", "taxable_year_start": "taxable year beginning before 1996-04-01",