Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200716022
Release Date: 4/20/2007
CC:TEGE:EOEG:ET1
POSTN-152483-06
UILC: 3231.01-00 date: January 9, 2007 to: Director, Submission Processing
Covington, KY
Attn: Entity Unit from: Office of Division Counsel/Associate Chief Counsel
Tax Exempt & Government Entities subject: Railroad Retirement Tax Act Status
In accordance with the coordination procedure established between the Service and the
Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act as of ---, the date it began operations:
---
---
---
---
We have reviewed the opinion of the RRB and, based upon the information submitted to us by the RRB, we also conclude that ---. became an employer under the Railroad Retirement Tax Act as of ---, the date it began operations.
POSTN-152483-06 2
However, we note that the opinion indicates that ---may be compensating its employees under the name of a sister company, ------ Please take the appropriate action regarding this business.
____
Janine Cook-