CCA 9933010: IRS concurs with Railroad Retirement Board employer classifications

Plain-English summary

The Railroad Retirement Board sent the IRS its opinion about the employer status of three redacted entities under the Railroad Retirement Act and Railroad Unemployment Insurance Act. Based solely on the submitted information, the IRS concurred that two entities became employers under those Acts and one ceased to be an employer. The publicly released memo omits the entities' names and effective dates. Employer classification matters for railroad employment tax treatment under section 3231.

Ruling snapshot

• Question: Did the IRS concur with the Board's employer status determinations?
• Outcome: Advice given; the IRS concurred based solely on the submitted information.
• Key authorities: IRC § 3231; Railroad Retirement Act; Railroad Unemployment Insurance Act.

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E WASHINGTON, D.C. 20224

MAY 5 1999

UILC: 3231.01-00
CC:EBEO:6
Number: 199933010
Release Date: 8/20/1999
MEMORANDUM FOR

FROM: Chief, Branch 6, Office of the Associate Chief Counsel
(Employee Benefits and Exempt Organizations)

SUBJECT:
Railroad Retirement Act Tax Status

Attached for your information and appropriate action is a copy of a letter from the Railroad Retirement Board concerning the status under the Railroad Retirement Act and the Railroad Unemployment Insurance Act of:

We have reviewed the opinion of the Railroad Retirement Board and, based solely upon the information submitted, concur in the conclusions that became an employer under the Railroad Retirement Act and the Railroad
Unemployment Insurance Act effective
and that
became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective We further
concur that
ceased to be an employer under the Acts
effective
.

HARRY BEKER