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Don't retaliate: Tennessee retaliatory tax improperly included Pennsylvania workers' compensation assessments
  • Eversheds Sutherland (US) 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
  • Eversheds Sutherland (US) 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


P.L. 86-27-who? Virginia Tax Commissioner determines single employee creates nexus
  • Eversheds Sutherland (US) 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


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

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


IRS rules on Section 419 funds utilizing cash value life insurance
  • Eversheds Sutherland (US) 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


The Sixth Circuit splits from the Federal Circuit and rules that severance payments are not taxable as FICA wages
  • Eversheds Sutherland (US) 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


Section 204(h) and lump sum guidance issued for defined benefit plans
  • Eversheds Sutherland (US) 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


Automatic contribution arrangements proposed regulations
  • Eversheds Sutherland (US) LLP
  • USA
  • November 9 2007

On November 8, 2007, the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) relating to automatic contribution arrangements


403(b) salary reduction agreement defined for FICA purposes
  • Eversheds Sutherland (US) 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


IRS publishes 403(b) model plan, orphan contract guidance
  • Eversheds Sutherland (US) 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