CCA 200651031: Business became a covered railroad retirement tax employer

Plain-English summary

The Railroad Retirement Board supplied an opinion that a business had become a covered employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. Chief Counsel reviewed that opinion and the Board's submitted information. It concluded that the business also became a covered employer under the Railroad Retirement Tax Act from the specified effective date. The employer's identity and date are redacted. The memorandum directs the IRS entity unit to take appropriate action and supplies no additional factual analysis.

Ruling snapshot

• Question: Has the business become a covered employer under the Railroad Retirement Tax Act?
• Outcome: Advice given: covered railroad retirement tax employer status begins on the redacted effective date.
• Key authorities: Railroad Retirement Tax Act; IRC § 3231 (indexed employer-status provision).

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200651031
Release Date: 12/22/06
CC:TEGE:EOEG:ET1
POSTN-139594-06

UILC: 3231.01-00

date: September 19, 2006
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 dated ------------------, that the following business became a covered 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 a covered employer under the Railroad Retirement Tax Act effective -----------------. Please take the appropriate action regarding this business.

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Janine Cook