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Wages

New verification code will appear on some 2015 W-2 forms

New verification code will appear on some 2015 W-2 forms

IRS website: IRS Tests W-2 Verification Code for Filing Season 2016  IRS is putting a new verification code on Copies B & C of some payroll firms’ W-2 forms in order to test its capability to verify the authenticity of Form W-2 data. The test is one in a series of steps IRS is taking […]

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State penalty for failure to pay terminated employee wasn’t FICA or FUTA wages

State penalty for failure to pay terminated employee wasn’t FICA or FUTA wages

Chief Counsel Advice 201522004 In Chief Counsel Advice (CCA), IRS concluded that payments (“late payment penalties”) that an employer was required to make under State (California) law to a terminated or quitting employee, because it failed to timely pay the employee’s final wages, weren’t wages for purposes of the Federal Insurance Contributions Act (FICA), the […]

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Court of Appeals Affirms: International Flight Attendant’s Wages Are Only Partially Excludable

Court of Appeals Affirms: International Flight Attendant’s Wages Are Only Partially Excludable

Rogers v. Comm., (CA Dist Col 4/17/2015) 115 AFTR 2d ¶2015-644 The Court of Appeals has affirmed a Tax Court decision that a U.S. citizen, based in Hong Kong and working as a flight attendant on U.S.-Asia flights, could not use the foreign earned income exclusion to shield all of her wages from U.S. income […]

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Court of Appeals affirms: international flight attendant’s wages are only partially excludable

Court of Appeals affirms: international flight attendant’s wages are only partially excludable

Rogers v. Comm., (CA Dist Col 4/17/2015) 115 AFTR 2d ¶2015-644   The Court of Appeals for the District of Columbia Circuit has affirmed a Tax Court decision that a U.S. citizen, based in Hong Kong and working as a flight attendant on U.S.-Asia flights, could not use the foreign earned income exclusion to shield […]

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U.S. permanent resident can’t exclude wages received from U.N. Mission

U.S. permanent resident can’t exclude wages received from U.N. Mission

Abrahamsen, (2014) 142 TC No. 22. The Tax Court has determined that a Finnish citizen who obtained permanent U.S. resident status, which entailed waiving her entitlement to “all rights and exemptions” available by virtue of occupational status, wasn’t entitled under Code Sec. 893 to exclude from income wages that she received in later years from […]

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Court upholds rule that imposed FICA tax on wages taxpayer will never receive

Court upholds rule that imposed FICA tax on wages taxpayer will never receive

Balestra (Ct Fed Cl 5/31/2014) 113 AFTR 2d ¶ 2014-887.  The Court of Federal Claims has rejected a taxpayer’s interpretation of Code Sec. 3121(v)(2), the Code section that imposes FICA tax on deferred compensation, and upheld the validity of the reg under that Code section, with the result that taxpayer was liable for FICA tax […]

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Distributions from S corporation to its president were wages, not loan repayments

Distributions from S corporation to its president were wages, not loan repayments

The Tax Court has held in Glass Blocks Unlimited v. Commissioner, T.C. Memo 2013-180, that distributions from an S corporation to its president/sole shareholder were taxable wages. IRS’s determination that the president was an employee was uncontested, and the S corporation failed to show that any portion of the distributions reflected repaid loans or that […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney