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Results: 1-10 of 57

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


P.L. 86-27-who? Virginia Tax Commissioner determines single employee creates nexus
  • Sutherland Asbill & Brennan LLP
  • USA
  • November 26 2013

The Virginia Tax Commissioner found that a corporation with a single employee in Virginia who conducted work-related activities from a Home Office


FATCA proposed legislation enacted as part of HIRE Act
  • Sutherland Asbill & Brennan LLP
  • USA
  • March 18 2010

On March 18, 2010, the President signed into law the Hiring Incentives for Restoring Employment Act (H.R. 2847) (“HIRE Act”), which incorporated the anti-avoidance revenue provisions previously contained in the proposed Foreign Account Tax Compliance Act (“FATCA”


Supreme Court holds Chevron deference applicable to “interpretive” regulations
  • Sutherland Asbill & Brennan LLP
  • USA
  • January 26 2011

The U.S. Supreme Court’s recent decision in Mayo Found. for Medical Education and Research v. United States (January 11, 2011), on the standard of deference for judicial review of “interpretive” tax regulations, will inform both the future regulation-writing process for and challenges to employee benefit and executive compensation tax regulations


Neither a Partner nor Employee Be: Treasury and the IRS Issue Regulations Clarifying the Employment Tax Treatment of Partners in Partnerships
  • Sutherland Asbill & Brennan LLP
  • USA
  • May 5 2016

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued temporary regulations (Regulations) clarifying the federal


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


IRS publishes 403(b) model plan, orphan contract guidance
  • Sutherland Asbill & Brennan LLP
  • USA
  • November 28 2007

On November 27, 2007, the Internal Revenue Service released Revenue Procedure 2007-71, elaborating in certain respects the final section 403(b) regulations published in July


403(b) salary reduction agreement defined for FICA purposes
  • Sutherland Asbill & Brennan LLP
  • USA
  • November 26 2007

On November 15, 2007, the Treasury and Internal Revenue Service published final regulations defining section 403(b) 'salary reduction agreements' for FICA purposes


MTC drafts model statute for wage withholding on mobile workers
  • Sutherland Asbill & Brennan LLP
  • USA
  • January 19 2010

The Multistate Tax Commission (MTC) Income and Franchise Tax Uniformity Subcommittee is considering a "Draft Model Mobile Workforce Statute."