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Clergy Housing Calculator — adversarial rules review

  • Reviewer: Claude Opus 5.5 (independent adversarial review)
  • Date: 2026-09-25
  • Files reviewed (not edited):
    • sources/clergy-housing.yaml
    • sources/clergy-housing-test-cases.yaml
    • sources/clergy-housing-open-questions.md
  • Primary sources fetched this session:
    • ITA s.8 (Justice Laws)
    • CRA Form T1223 E (24) PDF
    • CRA line 23100 page (modified 2026-01-20)
    • CRA payroll page on clergy residence (modified 2026-01-16)
    • Revenu Québec TP-76-V page and PDF (2016-10)
    • IRS Pub 517 (2025)
    • IRS Pub 1828 PDF (Rev. 8-2015)
    • 26 CFR 1.107-1 (Cornell LII)
  • Not re-fetched:
    • §107 and §1402(a)(8). The quoted text in the rules file matches my reading of the statute, and IRS Pub 517/1828 corroborate it.
    • Gaylor cert status. I could not verify it: the web-search budget was exhausted, and FFRF and CourtListener returned 403.

Totals: 5 critical · 9 major · 9 minor

1. Findings​

F-01 — CRITICAL — CA-06, CA-07, CA-TC-12, Open Question 1: the mixed-year Part (B) uses period-only remuneration and months, which contradicts the form​

Problem

For a year that is part employer-provided and part rented or owned, the calculator restricts two Part (B) lines to the rented/owned sub-period:

  • Line 1 (remuneration)
  • Line 3 (months)

For example, CA-TC-12 uses $27,500 and 6 months.

The current T1223 restricts only Line 6, the rent or fair rental value (FRV), to the period the residence was owned or rented:

  • Line 1 is "Income from qualifying employment from all eligible employers", which Note 1 equates with "remuneration for the year".
  • Line 3 is "Number of months in qualifying employment", not months in the residence.
  • The form asks the months-occupied question separately, and that answer feeds no line.

The statute's (A)(I) likewise counts "months ... in the year, during which the taxpayer is a person described in subparagraphs (i) and (ii)". That is clergy status, not tenure in the residence.

Counter-example: the calculator's method gives a lower number than the form

Full-year remuneration is $55,000. Jan–Jun is employer-provided, with a box 30 benefit of $7,000. Jul–Dec is rented at $12,000, and period remuneration is $27,500.

  • Calculator's method: 1/3 × 27,500 = 9,166.67; 6 × 1,000 = 6,000; greater-of = 9,166.67; lesser of that and 12,000 = 9,166.67. Plus A = $16,166.67.
  • Form-literal: 1/3 × 55,000 = 18,333.33; 12 months gives 10,000; greater-of = 18,333.33; lesser of that and 12,000 = 12,000; Line 10 = min(55,000, 12,000) = 12,000. Plus A = $19,000.00.

The pastor is under-deducted by $2,833.33.

Source

https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t1223/t1223-24e.pdf. Verbatim:

"Income from qualifying employment from all eligible employers (see note 1) 1 … Number of months in qualifying employment 3 … Actual rent and eligible utilities paid or, if residence is owned, fair rental value including eligible utilities for the total period in the year that the residence was owned or rented and you were in qualifying employment … 6"

"How many months did you ordinarily occupy this residence during the year?" (an unnumbered question that feeds no line)

ITA 8(1)(c)(iv)(A)(I): "$1,000 multiplied by the number of months (to a maximum of ten) in the year, during which the taxpayer is a person described in subparagraphs (i) and (ii)".

Fix

  • In Part (B), Line 1 = full-year qualifying remuneration from all eligible employers.
  • Line 3 = months in the year that the status and function tests were met.
  • Only Line 6 is period-restricted.
  • Rewrite the CA-06 note and CA-07 accordingly.
  • Add the counter-example above as a test case, with an expected result of $19,000.00.

F-02 — CRITICAL — CA-05 (missing rule): a clergy couple sharing one residence​

Problem

T1223 Notes 2 and 4 set out a mandatory ordering when both spouses claim:

  • Each spouse enters the full rent or FRV on Line 6.
  • The higher-salary spouse computes first.
  • The lower-salary spouse must enter the higher-salary spouse's clergy deduction on Line 7.

The rules and the formula describe OTHER only as "e.g., a work-space-in-the-home business expense claim". A calculator that does not ask whether the spouse is also clergy and claiming will give the lower-paid spouse a deduction that double-counts the same rent. That is a wrong number.

The statute confirms that only the taxpayer's own 8(1)(c) deduction is excluded from (B)(II).

Source

T1223 (24), Note 4:

"If you and your spouse or common-law partner are both claiming clergy residence deductions, the person with the higher salary should complete their calculation of the deduction first, with "0" entered on line 7 … The person with the lower salary should then take into consideration the clergy residence deduction made by the person with the higher salary…"

ITA 8(1)(c)(iv)(B)(II): "(other than an amount deducted under this paragraph by the taxpayer)".

Fix

  • Add rule CA-12 covering the spousal ordering.
  • Add an input: "Is your spouse also claiming this deduction for this home?"
  • If yes, include the spouse's deduction on Line 7 for the lower earner.
  • Add a test case with an expected result. For example:
    • Spouse A earns $60,000 and B earns $30,000; rent is $15,000.
    • A: max(20,000, 10,000) = 20,000 vs 15,000, so $15,000.
    • B: max(10,000, 10,000) = 10,000 vs (15,000 − 15,000) = 0, so $0.

F-03 — CRITICAL — CA-QC-01, CA-TC-09: Québec eligibility omits the "required to use the residence" condition​

Problem

The current TP-76-V makes the Québec deduction conditional on the employee being required to use the residence in the course of the office or employment. The employer does not even complete Part 2 if the answer is no. This has no federal counterpart.

CA-QC-01 softens the condition to "used in connection with". CA-TC-09 awards a Québec deduction of $12,000 without the input ever being asked. For a Québec pastor whose employer answers "No", the correct Québec figure is $0, and the federal figure stays at $12,000.

Source

https://www.revenuquebec.ca/documents/en/formulaires/tp/tp-76-v%282016-10%29.pdf:

"In addition, you must be required to use the residence or lodgings for which you are claiming a deduction in the course of your office or employment."

Part 2:

"You do not need to complete or sign this form if your employee was not required to use his or her residence or lodgings in the course of his or her office or employment."

Fix

  • Add a Québec-only required-use gate.
  • Add a CA-TC-09 variant in which required use = false, giving federal $12,000 and Québec $0.
  • Re-word CA-QC-01 to quote the condition.

F-04 — CRITICAL — CA-05 (missing eligibility test): principal place of residence, ordinarily occupied​

Problem

The (iv) branch applies only to the taxpayer's principal place of residence, ordinarily occupied during the year. Neither the rules nor the inputs capture this. A pastor could enter rent for a second home or cottage, or for a manse they do not live in, and receive a deduction.

Source

ITA 8(1)(c)(iv), https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-8.html:

"rent and utilities paid by the taxpayer for the taxpayer's principal place of residence (or other principal living accommodation), ordinarily occupied during the year by the taxpayer, or the fair rental value of such a residence … owned by the taxpayer or the taxpayer's spouse or common-law partner"

Fix

  • Add the condition to CA-05 or a new CA-rule, and add an eligibility question.
  • The calculator should state "one principal residence only".

F-05 — CRITICAL — US-07: the minister eligibility test is incomplete​

Problem 1: licensed and commissioned ministers

US-07 treats "ordained, commissioned, or licensed" as sufficient. Pub 517 adds a binding condition for denominations that ordain some ministers and license or commission others: the licensed or commissioned person must be able to perform substantially all the religious functions of an ordained minister. A licensed youth worker or commissioned staff member in such a denomination could wrongly be told they qualify.

Problem 2: the services condition

The exclusion also requires compensation for services that are "ordinarily the duties of a minister". A title alone is not enough. US-07 mentions this only in its notes.

Source

https://www.irs.gov/publications/p517 (2025):

"If a church or denomination ordains some ministers and licenses or commissions others, anyone licensed or commissioned must be able to perform substantially all the religious functions of an ordained minister to be treated as a minister."

Pub 1828 (Rev. 8-2015), p.22:

"…as part of the minister's compensation for services performed that are ordinarily the duties of a minister."

Fix

  • Add both conditions to the US-07 rule text.
  • Add an eligibility question for licensed or commissioned ministers.

F-06 — MAJOR — CA-11: the CPP/payroll mechanics are reversed and the EI statement is wrong​

Problem

CA-11 gets both payroll scenarios backwards and treats EI as unknown:

  • Owned or rented residence. CA-11 says the employer may reduce CPP and tax withholding by T1223 "line 11" on the employee's written confirmation. CRA actually requires the employee to send Form T1213 and T1223 to CRA and give the employer a CRA letter of authority. The reduction is limited to the amount on that letter.
  • Employer-provided residence. CA-11 says the inclusion and deduction "offset, so no separate adjustment ... is normally needed". This is the scenario where CRA allows the written-notice reduction.
  • EI. A cash housing allowance is insurable (box 24 included). A non-cash benefit is insurable only when cash is also paid in the pay period. Open Question 4 treats EI as unknown; it is answered.

Source

https://www.canada.ca/en/revenue-agency/services/tax/businesses/topics/payroll/benefits-allowances/boarding-lodging/housing-utilities/clergy-residence.html (modified 2026-01-16).

On an owned or rented residence:

"you can reduce the income used to calculate the employee's income tax deductions and CPP contributions if your employee does all of the following: … Completes Form T1213 … Sends Forms T1213 and T1223 to the CRA … Your employee provides you with the CRA letter of authority … You can only reduce the income used to calculate the income tax deductions and CPP contributions by the amount indicated on the letter of authority."

On employer-provided housing:

"do not include the housing or utilities share of the benefit that is equal to the clergy residence deduction in your employee's income when you calculate the employee's income tax deductions and CPP contributions if your employee does both of the following…"

On EI, the non-cash benefit status is: "EI (do not withhold unless cash earnings were also paid in the pay period)".

Fix

  • Rewrite CA-11 with the two correct scenarios.
  • State that cash allowances are EI-insurable and that the deduction does not reduce insurable earnings.
  • Also reduce the T4 box 26 claim to "reduced by the authorized amount".

F-07 — MAJOR — CA-04, CA-05, CA-06, CA-08, CA-09: stale, non-primary source, and the line numbers shown to users are wrong​

Problem

The rules cite T1223 E (20) from cchwebsites.com, which is a third-party mirror, not CRA. The current CRA form is T1223 E (24), and it has 10 lines, not 11:

  • Line 9 = lesser of Line 5 or Line 8.
  • Line 10 = lesser of Line 1 or Line 9, carried to line 23100.

The rules require the calculator to "implement the exact 11-line cascade". Any help text that says "enter Line 11 on 23100" will not match the form the pastor has in hand.

The arithmetic is equivalent: MIN(RENT, L9) is redundant when OTHER ≥ 0. However, OTHER must also be floored at 0; see F-15.

The CRA payroll page still says "line 11 of Form T1223". That is a CRA-internal inconsistency, so it should not be copied into user text.

Source

https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t1223/t1223-24e.pdf (footer "T1223 E (24)"):

"Enter whichever is less: Line 5 or line 8 9 / Line 1 or line 9 Enter the amount from line 10 on line 23100 of your return."

Fix

  • Re-cite every CA rule to the canada.ca (24) PDF.
  • Change CA-05 to the 10-line structure. Keeping the extra MIN is harmless, but label it as non-form.
  • Update the CA-06 excerpt to the (24) wording: "cannot be more than the income from qualifying employment on line 1".

F-08 — MAJOR — US-06, US-TC-03, US-TC-04, US-TC-11: the excess allowance is measured against the designated amount instead of the allowance paid, and the reasonable-salary term is dropped​

Problem

Pub 517 defines the taxable excess as the rental allowance [paid] minus the smallest of three amounts:

  • reasonable salary
  • FRV plus utilities
  • the amount actually used

US-06 uses designated_amount. When a church designates more than it actually pays, which is common because churches designate a high ceiling, the formula invents taxable income that was never received. This is wrong-number risk for the "excess" output.

Source

https://www.irs.gov/publications/p517:

"You must include in gross income the amount of any rental allowance that is more than the smallest of: Your reasonable salary, The fair rental value of the home plus utilities, or The amount actually used to provide a home."

Fix

  • Add an input allowance_actually_paid.
  • Set exclusion = MIN(designated, paid, actually_used, FRV).
  • Set excess = paid − exclusion.
  • Keep the reasonable-salary warning qualitative, but note that Pub 517 lists it as a term.
  • Relabel US-TC-11 so that "designated" = "paid".

F-09 — MAJOR — US-10: the double-benefit rule is mis-described​

Problem

The Pub 1828 limitation, together with Pub 517's allocation rule (the Deason rule), concerns ministry business expenses allocable to tax-free housing income. It does not concern "housing expenses". The carve-out "nor to the calculation of net earnings from self-employment" means those business expenses remain fully deductible for SE tax.

US-10 instead says mortgage interest and taxes "remain part of net earnings from self-employment", which is garbled and misleading.

Source

Pub 517:

"If you receive a tax-free rental or parsonage allowance … you must allocate a portion of the expenses of operating your ministry to that tax-free income. You can't deduct the portion of your expenses that you allocate to your tax-free rental or parsonage allowance."

"You may deduct the home mortgage interest and real estate taxes paid on your home even though you pay all or part of those expenses with funds you get through a tax-free rental or parsonage allowance."

Fix

Split US-10 into two rules:

  • (a) Mortgage interest and real-estate tax stay itemizable. Add the caveat that this helps only if the minister itemizes, and that the SALT cap applies.
  • (b) Unreimbursed ministry business expenses are partly disallowed for income tax in proportion to tax-free income, but are not limited for SE tax.

Delete the NESE sentence.

F-10 — MAJOR — US-08, Open Question 5: an unverified and likely wrong claim about cert denial, and a Wikipedia source​

Problem

The rules and Open Question 5 assert that the Supreme Court "denied certiorari ... October 2019 (140 S. Ct. 56)". I could not verify this; the search budget was exhausted and the case databases returned 403. My recollection is that FFRF announced it would not seek Supreme Court review after the 7th Circuit loss. If so, there was no cert petition to deny, and the citation is fabricated.

Either way, the rule's only source is Wikipedia, and Wikipedia does not mention any post-2019 event. I checked the same page today.

Source

https://en.wikipedia.org/wiki/Clergy_housing_allowance. The page ends at the 3/15/2019 7th Circuit ruling and has no Supreme Court entry.

Fix

  • Remove the cert-denial claim from the rules and the open questions entirely.
  • Cite only Gaylor v. Mnuchin, 919 F.3d 420 (7th Cir. 2019), and verify the reporter cite against the 7th Circuit opinion PDF before publishing.
  • Public wording: "upheld by the U.S. Court of Appeals for the Seventh Circuit in 2019; §107 remains in force."

F-11 — MAJOR — CA-QC-02: an internal contradiction about the remuneration cap on Line 11​

Problem

The rule text says the greater-of step with the case-V allowance is "subject to the overall remuneration cap", but the formula does not cap it. The current form does not cap Line 11 by Line 2 in the full-year case. Only mixed-year Line 13 does, as the lesser of Line 2 and Line 12. The two paths disagree for a Québec pastor whose case-V allowance is larger than their remuneration, which is rare.

Source

TP-76-V (2016-10):

"Enter the amount from line 9 or 10, whichever is greater. If you provided your own residence or lodging throughout the year, enter this amount on line 207 of your income tax return. 11"

"Enter the amount from line 2 or 12, whichever is less. Carry the amount to line 207 … 13"

Fix

  • Make the rule text match the form: no cap on Line 11 in a full year.
  • Add the Québec mixed-year section 1.2.3 (Line 12 = Line 1 + Line 11; Line 13 = MIN(Line 2, Line 12)) as a rule. It is currently missing.

F-12 — MAJOR — CA-QC-01: the Québec filing mechanics are misstated​

Problem

Québec requires a separate TP-76-V for each employer, enclosed with the return. The federal form uses one combined Part C instead. The rules and CA-TC-09 imply that Québec follows the federal combined model.

Source

TP-76-V (2016-10):

"Enclose the form with your income tax return. If you had more than one employer during the year, a separate form must be filed with regard to each one."

Fix

State the rule for multiple employers in Québec.

F-13 — MAJOR — US-02, US-TC-10: the "actually used" category list is presented as primary-sourced, but the sources do not list every category​

Problem

US-02 lists "real estate taxes, property insurance, furnishings, structural repairs" as if it were quoting Pub 517. The primary sources say something narrower:

  • Pub 517 (2025), as fetched, gives no itemized list.
  • Pub 1828 says "rent, mortgage payments, utilities, repairs and other expenses directly relating to providing a home".
  • Reg. 1.107-1(c) says rent, purchase, or "expenses directly related to providing a home", excluding food and servants.

US-TC-10 asserts that its categories are "all listed cost categories per Pub 517/Pub 1828". That overstates the sources.

Source

Pub 1828 p.22:

"Generally, those expenses include rent, mortgage payments, utilities, repairs and other expenses directly relating to providing a home."

26 CFR 1.107-1(c), per the Cornell LII fetch: the allowance is used to provide a home through "rent, purchase, or expenses directly related to providing a home", and does not include food or servants.

Fix

  • Cite the list to Pub 1828 and the Regulation verbatim.
  • Mark furnishings, insurance, and property tax as "directly related (commonly accepted)", not "listed".
  • Fix the US-TC-10 derivation wording.

F-14 — MAJOR — Open Question 3 / CA-QC-01: the "stale form" concern is resolved, and the wrong confidence level results​

Problem

The live Revenu Québec product page (fetched today with a browser user-agent) still lists TP-76-V, 2016-10 version as current, and titles the guide section "Residence Deduction for a Member of the Clergy or a Religious Order (Line 207)". The greater-of step with the case-V allowance and line 207 are therefore current, and confidence can be raised. The real Québec risks are F-03, F-11 and F-12, not staleness.

Source

https://www.revenuquebec.ca/en/online-services/forms-and-publications/current-details/tp-76-v/, verbatim: "PDF Document (92 KB) / TP-76-V / 2016-10 version … 4. Residence Deduction for a Member of the Clergy or a Religious Order (Line 207)".

Fix

  • Update the CA-QC notes and Open Question 3.
  • Re-cite to the English PDF tp-76-v(2016-10).pdf.

F-15 — MINOR — CA-05: OTHER must not produce a negative Line 8​

Problem

If OTHER is greater than RENT, Line 8 goes negative. The statute says "the amount, if any, by which ... exceeds", so the result is floored at 0. Without a floor, the formula can output a negative deduction, for example when the spousal Line 7 case from F-02 is larger than the rent.

Source

ITA 8(1)(c)(iv)(B): "the amount, if any, by which (I) … exceeds (II) …"

Fix

Use L8 = MAX(0, RENT − OTHER). Also clamp the final result at 0 or more.

F-16 — MINOR — CA-09: the statute and CRA's administrative position differ on filing​

Problem

ITA 8(10) says the prescribed form must be "filed with the taxpayer's return". CRA administratively says not to file it and to keep it instead. CA-09 is correct as practice, but it should acknowledge that the statute says otherwise, so that a treasurer is not confused.

Source

ITA 8(10):

"…shall not be deducted unless the taxpayer's employer confirms in prescribed form … and the form is filed with the taxpayer's return of income for the year."

T1223 (24): "You do not have to file this form with your … Return … However, you have to keep it…"

Fix

Add a note: keep the signed T1223; CRA waives physical filing.

F-17 — MINOR — CA-01, CA-02: IT-141R is called "operative" guidance, which overstates it​

Problem

CRA itself labels IT-141R "consolidated and archived". Archived bulletins are reference-only, so the rules should not call it "still the operative CRA interpretive guidance".

Source

T1223 (24): "For more information, see consolidated and archived Interpretation Bulletin IT-141R".

Fix

Reword as "archived; CRA still refers users to it on T1223".

F-18 — MINOR — CA-08, Open Question 2: the cash housing allowance question is answerable from a primary source​

Problem

The CRA payroll page's summary table shows "Housing allowance (cash): Box 14: included". A cash allowance is therefore employment income, and it is in Line 1. Confidence can move to high.

Source

CRA payroll page (F-06 URL). The treatment of cash housing allowance lists "Box 14: included".

T1223 Part C(A): "complete (B) below even if you received a housing allowance".

Fix

Raise the confidence and close Open Question 2.

F-19 — MINOR — US-03: the utility wording​

Problem

Pub 517 says that where the minister pays the utilities, an allowance designated for utilities is excludable "up to your actual cost". Utilities the church pays directly are part of the in-kind parsonage value. US-03's phrase "pays or reimburses utilities ... treated under §107(2)" lumps together direct payment by the church and a cash allowance.

Source

Pub 517: "If you pay for the utilities, you can exclude any allowance designated for utility costs, up to your actual cost."

Fix

Separate the two cases.

F-20 — MINOR — US (missing rule): retired ministers​

Problem

Pub 517 lets a retired minister exclude the part of their pension designated as a rental allowance. US-04 mentions retirement only for SECA purposes. Retired pastors are a common user group.

Source

Pub 517:

"If you are a retired minister, you can exclude from your gross income the rental value of a home (plus utilities) furnished to you by your church as a part of your pay for past services, or the part of your pension that was designated as a rental allowance."

Fix

Add rule US-11, and a flag for this case.

F-21 — MINOR — US-03, US-05, US-10: Pub 1828 is an old revision​

Problem

Pub 1828 is still at Rev. 8-2015. That is the current IRS PDF, downloaded today, but it is 11 years old. It should be secondary to Pub 517 (2025) wherever the two overlap.

Source

https://www.irs.gov/pub/irs-pdf/p1828.pdf, header: "Publication 1828 (Rev. 8-2015)".

Fix

Make Pub 517 (2025) the primary citation for US-02, US-03 and US-05, and keep Pub 1828 as corroboration.

F-22 — MINOR — Test-case header: rounding policy​

Problem

The header says "rounded to the nearest cent where division by 3 occurs". Rounding at an intermediate line can drift from the final figure by a cent. For example, L2 is rounded before it is compared with rent, so it can pass through to the result rounded early.

Fix

Specify: compute exactly, then round the final line-23100 figure half-up to the cent. None of the current cases change.

F-23 — MINOR — US-TC-10: the Schedule A claim​

Problem

mortgage_interest_and_property_tax_also_itemizable: true can be misread as a benefit. It is useful only if the minister itemizes rather than taking the standard deduction, and property tax is subject to the SALT cap. The input also combines "mortgage_principal_and_interest", but only the interest portion is itemizable.

Fix

  • Split principal from interest.
  • Add a note in the output: "only if you itemize".

2. Test-case recomputation — all 24 cases recomputed by hand​

Canada

CaseExpectedMy resultArithmeticMethod / rule status
CA-TC-0112,000.0012,000.00MatchOK
CA-TC-0216,666.6716,666.67MatchOK
CA-TC-0310,000.0010,000.00MatchOK
CA-TC-049,100.009,100.00MatchOK. This assumes the pastor was clergy for 7 months. If they were clergy all year and rented for only 7 months, Line 3 should be 12; see F-01.
CA-TC-0514,000.0014,000.00MatchOK
CA-TC-066,000.006,000.00MatchOK
CA-TC-070.000.00MatchOK
CA-TC-0816,000.0016,000.00MatchOK
CA-TC-09Fed 12,000 / QC 12,00012,000 / 12,000MatchMissing Québec required-use gate (F-03); per-employer filing (F-12)
CA-TC-1010,000.0010,000.00MatchOK
CA-TC-1112,000.0012,000.00MatchOK
CA-TC-1213,600.0013,600.00MatchCorrect by coincidence. The form-literal method (Line 1 = 55,000, 12 months) also gives 13,600 because rent binds. The stated method is wrong (F-01), and a case where it bites is needed.

United States

CaseExpectedMy resultArithmeticMethod / rule status
US-TC-0124,000 / 024,000 / 0MatchOK
US-TC-0218,000 / 018,000 / 0MatchOK
US-TC-0324,000 / 6,00024,000 / 6,000MatchExcess is correct only if the $30,000 was actually paid (F-08)
US-TC-0426,000 / 6,00026,000 / 6,000MatchSame as US-TC-03 (F-08)
US-TC-0520,00020,000MatchOK
US-TC-060 / 18,000 / 18,000 / 6,000SameMatchOK
US-TC-0740,000 / 20,000 / 60,000SameMatchOK
US-TC-0812,00012,000MatchOK
US-TC-0900MatchOK
US-TC-1028,00028,000 (sum checks: 18,000 + 4,000 + 1,000 + 3,000 + 1,500 + 500 = 28,000)MatchWording (F-13, F-23)
US-TC-1114,000 / 36,00014,000 / 36,000MatchAssumes designated = paid (F-08)
US-TC-129,000 + 15,400 = 24,40024,400MatchOK

Result: there are no arithmetic errors in any of the 24 cases. The problems are methodological: F-01, F-03 and F-08.

New cases to add

  • The mixed-year counter-example in F-01: expected $19,000.00.
  • The clergy-couple case in F-02: expected $15,000 and $0.
  • The Québec required-use = false case in F-03: expected federal $12,000, Québec $0.
  • A US case where the allowance paid is lower than the designated amount (F-08). For example:
    • Designated $30,000, paid $20,000, used $24,000, FRV $28,000.
    • Exclusion $20,000, excess $0.
    • The current formula wrongly gives $6,000.
  1. Mixed-year base (Open Question 1).
    • Use full-year qualifying remuneration for Line 1, and months in qualifying employment for Line 3, in Part (B).
    • Restrict only Line 6 to the rented or owned period.
    • Apply the final Part (C) cap against the same Line 1.
    • Source: T1223 E (24), Lines 1, 3 and 6, and Part (C); ITA 8(1)(c)(iv)(A)(I). See F-01.
  2. Cash housing allowance in Line 1 (Open Question 2).
    • It is included.
    • Source: the CRA payroll page lists a cash housing allowance as "Box 14: included". T1223 Part C(A) says to "complete (B) … even if you received a housing allowance". Close the question.
  3. Québec form currency (Open Question 3).
    • TP-76-V 2016-10 is the current version per the live Revenu Québec page, and the deduction goes on line 207.
    • The greater-of step with the case-V allowance is current.
    • Add the required-use gate (F-03), the rule for separate forms per employer (F-12), and mixed-year section 1.2.3 (F-11).
  4. CPP and EI (Open Question 4).
    • CPP can be reduced at source, and box 26 is reduced by the authorized amount.
      • For an employer-provided residence, this happens through the employee's written notice plus T1223.
      • For an owned or rented residence, it requires T1213, a CRA letter of authority, and the letter's amount.
    • EI is not reduced. A cash allowance is insurable; a non-cash benefit is insurable only if cash is paid in the same pay period.
    • Source: the CRA payroll page (F-06).
  5. Gaylor (Open Question 5).
    • Do not publish any cert-denial claim or the "140 S. Ct. 56" cite. They are unverified, and I believe FFRF did not petition.
    • Publish only "upheld by the 7th Circuit, Gaylor v. Mnuchin, 919 F.3d 420 (2019)", after checking the reporter cite against the ca7.uscourts.gov opinion.
  6. Reasonable compensation (Open Question 6).
    • Agree that it should stay qualitative.
    • Note that Pub 517 lists "Your reasonable salary" as one of the terms in the smallest-of test for the excess (F-08).
  7. Cost categories (Open Question 7).
    • Anchor to Pub 1828 ("rent, mortgage payments, utilities, repairs and other expenses directly relating to providing a home") and Reg. 1.107-1(c) ("expenses directly related to providing a home", excluding food and servants).
    • Present furnishings, insurance, property tax and HOA dues as "directly related" examples, not as a list from a primary source.
    • Pub 517 (2025), as fetched, gives no enumerated list.
  8. Thresholds (Open Question 8).
    • Confirmed verbatim in the statute today: "$1,000 multiplied by the number of months (to a maximum of ten)" and "one-third of the taxpayer's remuneration". These are not indexed. Agree.