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Results: 1-10 of 44

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


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


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 releases Chief Counsel Advice on year-end bonus accruals
  • Sutherland Asbill & Brennan LLP
  • USA
  • December 14 2009

As the end of the year approaches, many companies are establishing a 2009 bonus accrual so that they can take a 2009 deduction for bonuses paid early in 2010


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


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”


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”


IRS implements information reporting for employer-owned life insurance
  • Sutherland Asbill & Brennan LLP
  • USA
  • November 19 2007

On November 13, 2007, the Treasury Department and Internal Revenue Service published in the Federal Register temporary and proposed regulations implementing information reporting requirements for employer-owned life insurance, enacted in the Pension Protection Act of 2006


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