Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200738012
Release Date: 9/21/2007
CC:TEGE:EOEG:ET1
POSTN-113880-07
UILC: 3231.01-00 date: May 21, 2007 to: Director, Submission Processing
Cincinnati, OH
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 effective ---:
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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 effective ---.
However, the RRB opinion indicates that ---
---is wholly owned by ---. Thus, ---
--- may be disregarded as a separate entity for employment tax purposes. In such case, ---may be filing the necessary tax returns under the Railroad Retirement Tax Act. Please take the appropriate action regarding this business.
POSTN-113880-07 2
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Janine Cook cc: ---
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