Quality Stores Day Of Reckoning Draws Near – What Should Employers Be Thinking About?

By Phil Karter The Quality Stores employment tax refund case was argued before the Supreme Court on January 14, 2014.  An explanation about the issue at stake can be found in prior Taxblawg.net postings.  Although the outcome of the case remains in doubt, the possibility of a taxpayer victory means that employers should start thinking … More Quality Stores Day Of Reckoning Draws Near – What Should Employers Be Thinking About?

Are Quiet Disclosures of Offshore Accounts Becoming Even Riskier?

By Phil Karter Is the IRS getting closer to ferreting out “quiet disclosures” by taxpayers who chose that route to address the problem of previously unreported offshore accounts rather than by participating in the Service’s offshore voluntary disclosure program (OVDP)?  That’s the conclusion of an increasing number of tax professionals and if taxpayers in this … More Are Quiet Disclosures of Offshore Accounts Becoming Even Riskier?

Filing Tax Returns During the Silly Season

For my fellow procrastinators whose federal tax returns are on extension, with the October 15th deadline rapidly approaching, perhaps the burning question has crossed your mind, “If I file electronically while the government is shut down, will my return be accepted?”  Yes, I can happily report that a return electronically submitted to the IRS at 3:43 … More Filing Tax Returns During the Silly Season

Squib Note: The Opera Isn’t Over Yet on FICA Tax Refunds Until The Supreme Court Sings

By Phil Karter and John Hackney In a blog posting earlier this year, we talked about the Sixth Circuit’s decision in United States v. Quality Stores (Civil No. 10-1563, 6th Cir. 2012) affirming a lower court’s decision that supplemental unemployment compensation benefit (SUB) payments are not taxable as wages and are consequently exempt from FICA … More Squib Note: The Opera Isn’t Over Yet on FICA Tax Refunds Until The Supreme Court Sings

Sixth Circuit Moves The Ball Forward For Companies Seeking FICA Tax Refunds On Supplemental Unemployment Compensation Benefit Payments

By Phil Karter and John Hackney For companies that have implemented employee layoffs in the past several years and made severance payments to terminated employees, the prospect of eligibility for federal tax refunds for any FICA taxes withheld from such payments took another step forward with the Sixth Circuit’s January 4th denial of the government’s … More Sixth Circuit Moves The Ball Forward For Companies Seeking FICA Tax Refunds On Supplemental Unemployment Compensation Benefit Payments

Could The New Economic Substance Statute Apply To End-Of-Year Stock Sales And Repurchases?

By Phil Karter With the looming increase in tax rates on investment income and capital gains in particular, a large number of stock market investors have been selling long-term positions to lock in the 2012 rate, which currently tops out at 15%.  Come January 1,2013, gain on the same sale could be taxed at a … More Could The New Economic Substance Statute Apply To End-Of-Year Stock Sales And Repurchases?

If The Job Offer Includes A Loan From The Employer, Talk To Your Tax Adviser Before Accepting!

By George W. Connelly It is not uncommon for sought-after job seekers to receive what appears to be an offer that is too good to be true:  in addition to a good compensation and benefits package, the employer proposes to make a loan to the applicant, and to forgive the entire amount if the person stays … More If The Job Offer Includes A Loan From The Employer, Talk To Your Tax Adviser Before Accepting!