Non-elective Contributions to a Church Plan

[Guest Keith Hindman]

If a church 403(B) plan chooses to make a non-elective, non-matching contribution to an account as an incentive for retirement savings for pastors, is that deposit subject to the maximum contribution limits of 403(B), 402(g) and 415©? This could be either a one-time initial contribution for new pastors, or an annual deposit for all eligible pastors in the denomination.

Many pastors find themselves employed by congregations that may not pay any salary, but might provide a housing allowance or expense reimbursements which are not part of includible compensation. It seems logical that if there is no includible compensation, there can be no exclusion allowance, and thus, no contribution to the plan. I would appreciate any comments.