© Morgan, Lewis & Bockius LLP Wage Recharacterization Audits: Choices between Cash and Code § 132(d) Benefits At a 2007 meeting of the Fringe Benefit Tax Section of the American Bar Association, IRS attorneys present conceded that there were practical difficulties with enforcing an absolute prohibition on wage recharacterization; they also admitted that if an arrangement was properly structured, it would be unlikely to be challenged by the IRS on audit.
{"Image DocumentName": "Final Shared Responsibility Rules", "Image ImageDescription": "Confirms 2015 Shared Responsibility effective date for large (100 or more FTE/FTeq) employers. Expands proposed 95/5% offer rule to 70/30% for 2015, but can still lead to inadequate coverage penalty. The 70% expansion creates new planning opportunities. Delays Shared Responsibility effective date until 2016 for mid-size employers (50 to 99 FTE/FTeq) Numerous requirements and a necessary certification in order to qualify. Places new emphasis on when an employer is small enough to escape Shared Responsibility rules for 2015.", "Image XResolution": "37", "Image YResolution": "37", "Image ResolutionUnit": "Pixels/Centimeter", "Image Software": "SlidePlayer", "Image YCbCrPositioning": "Centered"}