CCA 200706009: Railroad employer coverage ends with separate last-pay date noted

Plain-English summary

The Railroad Retirement Board advised that a business had ceased to be a covered employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. Chief Counsel reviewed the opinion and agreed that the business also ceased to be a covered employer under the Railroad Retirement Tax Act. The memorandum separately noted that employees might have been last compensated on another redacted date. It directed the IRS processing unit to take the appropriate action for the business.

Ruling snapshot

• Question: Did the business cease to be a covered railroad retirement tax employer?
• Outcome: Advice confirming the end of covered-employer status, while separately noting a possible last-compensation date.
• Key authorities: Railroad Retirement Tax Act employer status; coordination with the Railroad Retirement Board; UILC 3231.01-00.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200706009
Release Date: 2/9/2007
CC:TEGE:EOEG:ET1
POSTN-139588-06

UILC: 3231.01-00

date: October 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 that the following business ceased to be a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective close of business ------------------
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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 the ----------------------------------------ceased to be a covered employer under the jurisdiction of the Railroad Retirement Tax Act on ------------ --------------------------. However, we note that the employees may have been last compensated on ---------------------. Please take the appropriate action regarding this business.

_____
Janine Cook