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Can a minister give cash from a discretionary fund to an employee — yes, but there are tax consequences

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The claim by Beth Colley of St Andrews Anglican Church in Mt Pleasant that the cash gifts given by then Bishop Steve Wood, rector of the parish, to Claire Buxton, a parish employee were above board raises questions about the business and accounting standards of that institution.

Ms Colley, the chief operating officer of St. Andrew’s, stated in a letter to the editor of the Washington Post that “There was nothing inappropriate about our senior pastor’s distribution of financial assistance to a female member of our staff.”

She notes the parish has a well established program of helping “parishioners and staff members who face financial hardship.”

“To characterize this compassion as something improper misunderstands both the intent and the integrity of our community. At its heart, the ministry of St. Andrew’s strives to care thoughtfully and holistically for those in our congregation and our wider community. Extending financial assistance in times of crisis is one of the most tangible ways a church can embody the gospel it proclaims”, she stated

Such sentiments are indeed praise worthy, but they do raise the question of whether the parish is in compliance with Federal law.

Internal Revenue Code (IRC) § 102(c) states that cash or non-cash gifts from an employer to an employee must be treated as taxable income, subject to withholding and reporting requirements.

Specifically, it states: “Subsection (a) shall not exclude from gross income any amount transferred by or for an employer to, or for the benefit of, an employee.”

In other words, any gift from an employer to an employee is considered taxable income unless specifically excluded by another section of the tax code. Such gifts must be reported as wages and are subject to federal income tax withholding, Social Security, and Medicare taxes. Non-cash gifts are also generally taxable unless they qualify as a “de minimis fringe benefit” under IRC § 132(a)(4). See: IRC § 102(c): Gifts from employers to employees are not excludable from gross income; IRS Publication 15-B (2025), Employer’s Tax Guide to Fringe Benefits; IRS Publication 525, Taxable and Nontaxable Income.

These citations provide the authoritative foundation for the IRS position that most gifts from employers to employees are taxable, subject to reporting and withholding.

Did St Andrew’s report the $3500 gifts to Claire Buxton as income? The Constitution and Canons of the Diocese of the Carolinas are silent on the topic of discretionary funds. Again, while the intent may have been noble – no one knows what was in the mind of Bishop Wood when he gave the money to Claire Buxton – there are proper ways to do it – and based on the facts at hand, this didn’t happen.

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