difference between church and ministry

Starting a new church takes a lot of hard work. I know because I have done it 3 times. While one church plant went well, the other two did not. It was during the planting phase of one of the less successful church plants that I took to Google to explore different strategies and philosophies on church planting. One strategy caught my attention, and upon further reading immediacy dismissed. The strategy goes like this; partner with one or more existing churches to help with the new church start. While this theory seems perfectly logical, and a fast way to church growth, it does pose a rather unpleasant and unexpected outcome that many church plants do not take into account is that the IRS has very distinct requirements for churches, and that is that the members can only belong to one church. In other words, using this model, if you have 100 members of a church plant, and those members are from other churches and do not transfer membership, at least until the church plant grows to a point it can sustain itself, then the church has the chance of being reclassified by the IRS as a ministry or other religious organization.  The general rule is that the majority of the members of a church has to be a member of ONLY that church, if this is reversed and the majority of congregation belongs to another church, it is considered a ministry and will have to apply for its own 501c3 status as well as file an annual 990 report.