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Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Employers Are Obligated to Comply with Tax Law Despite Increase in Frivolous Tax Arguments

In the recent United States Tax Court case O’Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax....more

IRS Updates Guidance on Section 530 and Worker Status Issues

The Internal Revenue Service has released new guidance, Rev. Rul. 2025-3, clarifying the application of Section 530 of the Revenue Act of 1978, Section 3509 of the Internal Revenue Code (IRC), and Section 7436 of the IRC in...more

IRS Ruling Clarifies Employment Tax Implications of Paid Family and Medical Leave Programs

The IRS’s recently released Revenue Ruling 2025-4 provides significant guidance on the employment tax treatment of contributions to and benefits paid under state paid family and medical leave (PFML) programs. This has been an...more

Dear Littler: What are the tax implications of office gift-giving and donation matching?

Dear Littler, We’d like to provide gifts to our staff for the holidays but are unsure which types of gifts would trigger tax obligations for our employees. We’d also like to offer donation matching for our employees’...more

IRS Updates FAQs on 1099-Ks Used for Gig Workers and Others

The IRS recently updated its guidance for completing Form 1099-K, used primarily by “gig” companies providing compensation using payment apps or online marketplaces and for individuals selling goods on online marketplaces...more

Watch Out New York – New Jersey Wants Its Taxes Too!

On July 21, 2023, New Jersey Governor Phil Murphy signed Assembly Bill No. S3128/A4694 into law, which implements an aggressive tax treatment of nonresidents who work for New Jersey employers.  The law essentially adopts the...more

Certificates of Coverage Necessary for Expatriate Workers to Claim FICA Exemption under Totalization Agreements

In an opinion issued on June 20, 2023, the United States Court of Federal Claims reminded taxpayers that they must obtain a certificate of coverage in order to claim an exemption from Social Security and Medicare taxes (FICA)...more

Department of Labor and IRS Intensify Cooperation on Worker Misclassification

On December 14, 2022, the U.S. Department of Labor (DOL) and the Internal Revenue Service (IRS) signed and published a Memorandum of Understanding for Employment Tax Referrals (the “MOU”). The MOU establishes a system for...more

New Jersey Quietly Rolls Back Temporary Suspension of Employer Withholding Rules for Teleworking Employees

Effective October 1, 2021, the New Jersey Division of Taxation (the “NJDT”) ended the temporary relief period with regard to employers’ obligation to withhold income taxes for teleworking employees who work in New Jersey.1 ...more

Tax Court Reiterates the Proper Tax Treatment of “Physical Injuries” in Employment Cases

In Stassi v. Commissioner, the United States Tax Court found that a settlement was not excludable from income as a personal physical injury because the taxpayer failed to demonstrate that her shingles was caused by her...more

Dear Littler: Are There Any Tax Implications Now That Our Employees Are Teleworking During The COVID-19 Crisis?

Dear Littler: Our company is based in New York City, but since March 20 our employees have been teleworking because of the “stay at home” orders necessary to combat the spread of COVID-19. Most of our employees are working...more

Dear Littler: Can Employees be Exempt from Income Tax?

Dear Littler: My company recently hired a new employee who is giving our human resources department some pushback on submitting his W-4. The HR manager says the employee mentioned something about not being subject to income...more

Dear Littler: 'Tis the Season…for Employer Holiday Gift-Giving Reminders

Dear Littler: I’m in charge of our company’s party-planning committee, but I’m ready to give up my title as Head Elf. We’re working on choosing gifts for employees, and we’d like to raffle off nice prizes for employees and...more

Ninth Circuit Orders Gross Ups for Back Pay Award

In a short published opinion, the U.S. Court of Appeals for the Ninth Circuit sided with the Third, Seventh and Tenth Circuits, and split with the D.C. Circuit, over whether a federal district court may award a “tax...more

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