United States , U. The court dismissed this contention with the suggestion that the exception was meant for cash payments generated by fractional shares payable to an employee in connection with the exercise of a qualified stock option. As the government pointed out, this is a remarkably narrow meaning to assign to this exception.
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The railroad pension plans federalized by the RRA defined compensation to exclude the value of these in-kind fringe benefits. Petition for Writ of Certiorari at 5.
The court does not explain how the RRB was so empowered to augment the statute. First, the court rejects the application of Chevron, U. Natural Res. Defense Council, Inc.
Accordingly, the decision does not invalidate the RRTA regulations but rather disagrees with how the IRS sought to apply those regulations to compensatory stock. That is, even if the drafters had a concept of money, it is not clear that the drafters meant to freeze that moment in time.
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Nevertheless, that is what the decision purports to do. This disconnect is likely negligible, however, because employees receiving stock compensation may well have exceeded both the RRTA Tier 2 taxable wage base and the Tier 2 maximum earnings base without regard to the stock compensation.
Further, unlike the Social Security Trust Funds, the railroad retirement system is currently projected to experience no cash flow problems during the next 25 years. The Wisconsin Central decision suggests that the IRS and other regulating agencies should expect more scrutiny of certain pragmatic regulatory interpretations.
Helps you know if you should do it yourself or hire a professional. While there are many encyclopedic books on taxes—like J. Far more than a rehash of impenetrable IRS "help" documents, Tax Insights is organized the way most people think and presents ideas in clear, simple language. If you buy this book and take advantage of its advice, you will save money.
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