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 … Continue reading Quality Stores Day Of Reckoning Draws Near – What Should Employers Be Thinking About?
The IRS released Notice 1036 to assist employer’s with determining the payroll tax consequences of the fiscal cliff. 2013 Withholding Tables. Notice 1036 includes the 2013 Percentage Method Tables for Income Tax Withholding. Employers should implement the 2013 withholding tables as soon as possible, but not later than February 15, 2013. Employers can use the … Continue reading The Moment You Have All Been Waiting For: Payroll Tax Guidance for 2013
The IRS recently announced in Notice 2011-12 that Notice 2009-91 will not apply to wages paid after December 31, 2010. Previously, Notice 2009-91 revised the withholding calculation rules for nonresident alien employees performing services within the United States. Notice 2009-91 revised the rules to take into account changes made in the withholding tables to reflect … Continue reading Revised Withholding Calculation Rules for Nonresident Alien Employees
By Jonathan Prokup It seems that one of our favorite topics is back in the news: the sourcing of guarantee fees. As reported in today’s Tax Notes, Robert Driscoll, withholding technical advisor for LMSB, was recently quoted as saying that guarantee fees might not be considered U.S.-source income if the guarantor is a qualified resident … Continue reading Curiouser and Curiouser: The Sourcing of Guarantee Fees Rises Again
By George W. Connelly As my readers know, I focus my practice on representing people who have “misunderstandings” with the Internal Revenue Service. I can’t count the number of clients who have made a comment along the lines of “get me Geithner’s deal” since it came to light that he had some significant and frankly embarrassing … Continue reading What Would Happen If A Taxpayer Asks The IRS For The Same “Deal” That Timothy Geithner Got?
By Jonathan Prokup In her column last Monday, Lee Sheppard criticized Judge Holmes of the Tax Court for, as she put it, “strain[ing] to find a reason to hold for the taxpayer” in the recent case of Container Corp. v. Comm’r, 134. T.C. No. 5. (For our prior discussion of this case, see here. For … Continue reading Lee Sheppard Takes on Container Corp.