We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 47

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


IRS extends and expands relief, seeks comments on Puerto Rico plans and group trusts
  • Sutherland Asbill & Brennan 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


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”


Automatic contribution arrangements proposed regulations
  • Sutherland Asbill & Brennan LLP
  • USA
  • November 9 2007

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


IRS announces Section 409A compliance program for discounted stock options
  • Sutherland Asbill & Brennan 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 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


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


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


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