Ezel / IRS Rulings / 201550036
Chief Counsel Advice 201550036 Released December 11, 2015 Advice

Employment tax employer regulations identified for review

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This page covers one taxpayer's ruling from 2015, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2015
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Following an employment tax discussion, Chief Counsel provided temporary regulations under IRC § 3501 and Announcement 85-113. It also identified portions of the regulations defining an employer under IRC § 3401(d) that might help resolve the question. The email did not state a final conclusion on the underlying facts.

Ruling snapshot

  • Question: Which employment tax authorities could help analyze who qualified as the employer?
  • Outcome: Advice given
  • Key authorities: IRC §§ 3401(d), 3501; Treas. Reg. §§ 31.3401(d)-1(f), 31.3401(d)-1(g), 3501(a)-1T; Announcement 85-113

Full text (IRS public release)

ID: CCA-07230412-15
UILC: 3401.00-00

Number: 201550036
Release Date: 12/11/2015
From: ------------------
Sent: Thursday, July 23, 2015 4:12 PM
To: ------------------------
Cc: ------------------------------------------
Bcc:
Subject: RE: --------------------Employment Tax Question

----------, thank you for taking the time to talk with us this afternoon. As promised,
attached are copies of §3501(a)-1T, Q&A-5 and Announcement 85-113, which we
referred to in our discussion. In addition, we promised to look at the section 3401(d)
regulations, and believe that §31.3401(d)-1(f) and the last sentence of §31.3401(d)-1(g)
may be helpful. Please let us know if there is anything more we may do. My telephone
number is --------------------. It was a pleasure talking with you, -------

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