Application of the Self-Employment Contributions Act (SECA) Tax to
I. Overview and Purpose
This notice sets forth a proposed revenue ruling concerning the
application of the Self-Employment Contributions Act (SECA) tax to payments
made by the U.S. Department of Agriculture (USDA) under the Conservation
Reserve Program (CRP), 16 U.S.C. 3831. CRP was authorized in 1985. It is
one of several programs administered by the USDA that provide payments in
exchange for diverting land from agricultural use to other uses.
The Service has previously issued an announcement addressing the
SECA tax treatment of payments made by the USDA under land diversion
programs. Announcement 83-43, 1983-10 I.R.B. 29, provides guidance in a
Question and Answer format related to land diversion programs sponsored by
the USDA for purposes of special use valuation under section 2032A of the
Code, estate tax deferral under section 6166 of the Code, and the SECA tax. In
Q&A 3, the Service stated that a farmer who receives cash or a payment in kind
from the USDA for participation in a land diversion program is liable for selfemployment tax on the cash or payment in kind received.
