Marianna Dyson Comments on IRS Support of Quality Stores Ruling in Tax Notes Today

"Following Quality Stores, SUB Benefit Exclusion Still Exists"
Tax Notes Today
02.11.15Marianna Dyson commented on the Internal Revenue Service's (IRS) recent announcement that it will fully disallow all claims for refund held in suspense following resolution of United States v. Quality Stores. The Supreme Court held that certain lump-sum severance payments paid to employees following the company's bankruptcy were wages subject to FICA taxes. The announcement confirms that employers may continue to rely on Revenue Ruling 90-72 to exempt SUB payments meeting the conditions of that ruling from FICA taxation. Because the government distanced itself from the IRS's rulings during the oral argument, it wasn't clear whether the IRS might follow suit, Dyson said, adding that the announcement makes certain that "the IRS has embraced this ruling."
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