Contributions by professional services corporation to trusts which fund severance, education and life insurance benefits held deductible under s. 162
Article Abstract:
Professional services corporations which fund employee fringe benefits by contributions to trusts which qualify as voluntary employees' beneficiary associations can now deduct such contributions under IRC 162. The case in question was Schneider v Commissioner, in which a medical practice was structured as a professional services corporation and most of the benefits went to the physician who was the corporation's owner and director. The IRS had sought to disregard the corporate entity and disallow the deductions, but the Tax Court held the contributions to be deductible.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1992
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Attorney taxed on income from personal services paid to his professional corporation
Article Abstract:
The IRS ruled in PLR 9514008 that an attorney employed by his own professional corporation was subject to taxation under the assignment of income doctrine for services performed as a corporate board member. The attorney had to serve on the board as a natural person, not as his personal services corporation, under state law, so fees were paid to him directly and then he passed them on to his corporation. The IRS ruled that the services performed were not sufficiently similar to those the attorney performed for his employer, the professional corporation.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1995
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Employer-provided outplacement services are nontaxable fringe benefits under Code s. 132
Article Abstract:
The IRS dealt with employers' outplacement services in Revenue Ruling 92-69 and decided that these services constitute a nontaxable fringe benefit when the employer obtains a real business benefit from them but that the employee has to recognize gross income when they are provided instead of increased severance payments. IRC 132 governs the exclusion of outplacement services as an employee fringe benefit.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1992
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- Abstracts: Reevaluating the grantor trust status of GRATs and QPRTs. Adult adoption may qualify one as a beneficiary. General powers of appointment may cause unexpected tax
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