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Results: 1-10 of 61

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 announces Section 409A compliance program for discounted stock options
  • Eversheds Sutherland (US) LLP
  • USA
  • February 12 2007

In Announcement 2007-18, the Internal Revenue Service (IRS) introduced a compliance resolution program that will permit employers to pay the additional taxes employees have incurred under section 409A of the Internal Revenue Code (the Code) as a result of exercising discounted stock options and stock appreciation rights during 2006


IRS extends and expands relief, seeks comments on Puerto Rico plans and group trusts
  • Eversheds Sutherland (US) LLP
  • Puerto Rico, USA
  • January 4 2012

IRS Notice 2012-6, to be published on January 17, 2012, extends and expands the transition relief provided under Rev. Rul. 2011-1 and Rev. Rul. 2008-40 for certain retirement plans that qualify under the Puerto Rico Internal Revenue Code and group trusts holding investments by such Puerto Rico-qualified plans


New worker classification procedures affect IRSDOL compliance and enforcement efforts
  • Eversheds Sutherland (US) 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


Supreme Court holds Chevron deference applicable to “interpretive” regulations
  • Eversheds Sutherland (US) 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
  • 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


IRS provides temporary relief for IRA cross-collateralization agreements
  • Eversheds Sutherland (US) 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


IRS proposes comprehensive cafeteria plan regulations
  • Eversheds Sutherland (US) LLP
  • USA
  • August 7 2007

Since Internal Revenue Code (“Code”) section 125 was enacted and cafeteria plans were first made available in 1978, the Internal Revenue Service has issued a grab bag of proposed regulations under Code section 125 but issued final regulations only for rules governing mid-year election changes (Treas. Reg. 1.125-4) and coordination of family medical leave with cafeteria plan coverage (Treas. Reg. 1.125-3


Ho-ho-hold the tax reporting: IRS further delays tax reporting for compliant deferred compensation
  • Eversheds Sutherland (US) LLP
  • USA
  • December 11 2008

On December 10, 2008, the IRS issued Notice 2008-115, which provides that tax reporting for 2008 will not be required for deferrals of compensation under nonqualified deferred compensation arrangements that comply with 409A of the Internal Revenue Code