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Results: 1-10 of 55

Virginia Tax Commissioner rules that compensation subject to Virginia income tax withholding cannot be used to calculate payroll factor
  • Sutherland Asbill & Brennan LLP
  • USA
  • September 14 2015

The Virginia Tax Commissioner upheld an upward adjustment to a taxpayer's payroll factor attributing to Virginia all compensation that the taxpayer


Don't retaliate: Tennessee retaliatory tax improperly included Pennsylvania workers' compensation assessments
  • Sutherland Asbill & Brennan LLP
  • USA
  • October 13 2015

The Tennessee Supreme Court held that the Tennessee Department of Commerce and Insurance (Department) improperly imposed retaliatory taxes on


The Home Stretch: Virginia Tax Commissioner Rules that Single Employee Working From Home Creates Nexus
  • Sutherland Asbill & Brennan LLP
  • USA
  • April 5 2016

The Virginia Tax Commissioner ruled that an out-of-state corporation had nexus with Virginia because an employee performed Accounting, human


IRS rules on Section 419 funds utilizing cash value life insurance
  • Sutherland Asbill & Brennan LLP
  • USA
  • October 22 2007

On October 17, 2007, the Internal Revenue Service issued a revenue ruling taking the position that an employer’s contribution to a welfare benefit fund may not be deductible, in whole or in part, under section 419 to the extent the fund pays premiums on cash value life insurance policies


IRS Notice 2007-86 provides general extension of 409A transition relief through 2008
  • Sutherland Asbill & Brennan LLP
  • USA
  • October 23 2007

In response to comments from the ABA Tax Section, benefits industry organizations, and law firms that the limited Internal Revenue Code section 409A transition relief for 2008 provided in September was inadequate, the IRS yesterday issued Notice 2007-86 (the “Notice”


The Sixth Circuit splits from the Federal Circuit and rules that severance payments are not taxable as FICA wages
  • Sutherland Asbill & Brennan LLP
  • USA
  • September 20 2012

On September 7, 2012, the Sixth Circuit held that certain types of severance payments (referred to as supplemental unemployment compensation or “SUB payments”) are not taxable wages under FICA


IRS provides temporary relief for IRA cross-collateralization agreements
  • Sutherland Asbill & Brennan LLP
  • USA
  • December 14 2011

In Announcement 2011-81 (December 12, 2011), the Internal Revenue Service granted temporary relief for an indemnity, security interest or other cross-collateralization agreement provided by an individual retirement account owner in circumstances similar to those addressed in U.S. Department of Labor Advisory Opinion 2009-03A and Advisory Opinion 2011-09A


New worker classification procedures affect IRSDOL compliance and enforcement efforts
  • Sutherland Asbill & Brennan LLP
  • USA
  • September 26 2011

On September 21, 2011, the Internal Revenue Service (IRS) introduced its new Voluntary Classification Settlement Program (VCSP), which provides meaningful tax relief for employers that agree to prospectively reclassify as employees workers previously treated as independent contractors


Section 204(h) and lump sum guidance issued for defined benefit plans
  • Sutherland Asbill & Brennan LLP
  • USA
  • November 7 2007

On November 6, 2007, the Internal Revenue Service addressed (through a posting on its website) whether an ERISA section 204(h) notice is required in 2007 for certain defined benefit plan amendments required by the Pension Protection Act of 2006


IRS provides limited relief and additional guidance under Code Section 409A - full analysis
  • Sutherland Asbill & Brennan LLP
  • USA
  • September 14 2007

A Legal Alert that we sent out on September 11, 2007 contained a high level summary of Notice 2007-78 (the "Notice"), which provides limited additional relief and guidance with respect to nonqualified deferred compensation plans under section 409A of the Internal Revenue Code