Jeffrey Holdvogt

Jeffrey Holdvogt

McDermott Will & Emery

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Supreme Court Decides in Favor of IRS in Quality Stores: FICA Generally Applies to Severance Payments

The Supreme Court of the United States has decided in favor of the Internal Revenue Service in United States v. Quality Stores, Inc., holding that severance payments made pursuant to plans that did not tie payments to the...more

3/27/2014 - FICA Taxes IRS Quality Stores SCOTUS Severance Pay

IRS Issues Final Regulations Clarifying Substantial Risk of Forfeiture Under Section 83 of the Internal Revenue Code

The Internal Revenue Service (IRS) recently released new final regulations under Section 83 of the Internal Revenue Code (the Code) that confirm several positions that it has successfully taken in litigation about what is ...more

3/10/2014 - Forfeiture IRC IRS

Deadline Looms for Quality Stores FICA Refund Claims for Severance Payments

The Supreme Court of the United States recently heard arguments in its review of the U.S. Court of Appeals for the Sixth Circuit’s Quality Stores decision. At issue in Quality Stores is whether certain severance payments...more

2/13/2014 - Deadlines FICA Taxes Income Taxes Quality Stores Wage and Hour

Employer Obligations for Additional Medicare Tax

The Internal Revenue Service recently released final regulations and updated questions and answers to help employers and taxpayers comply with the new 0.9 percent Medicare payroll tax increase on high-income earners that...more

12/10/2013 - Compliance IRS Medicare Payroll Taxes

IRS Announces Employee Benefit Plan Limits for 2014

The Internal Revenue Service (IRS) recently announced cost-of-living adjustments to the applicable dollar limits on various employer-sponsored retirement and welfare plans for 2014. Although many dollar limits currently in...more

11/1/2013 - 401k COLA Cost-of-Living Employee Benefits HSA IRS Retirement Plan

Additional Time for Employers to Amend and File Puerto Rico Qualified Retirement Plans

The Puerto Rico Treasury Department recently issued Circular Letter No. 13-02, extending the deadline for employers that sponsor qualified retirement plans benefiting Puerto Rico employees to adopt amendments and file for...more

7/16/2013 - Qualified Retirement Plans Retirement

Inside M&A - Spring 2013

Top Five Traps for the Unwary in Spin-Offs - A wave of corporate breakups has swept through the United States over the last few years as investors have taken notice of the fact that smaller companies focused on a...more

4/30/2013 - Disclosure Requirements Employee Benefits Incentives Private Letter Rulings Restructuring Separate Accounts Separation Spinoffs Tax Exemptions

IRS Provides Additional Favorable Guidance on Recently Modified Voluntary Classification Settlement Program

On February 27, 2013, the Internal Revenue Service (IRS) issued News Release IR-2013-23 to provide additional favorable guidance regarding modifications to the Voluntary Classification Settlement Program (VCSP) issued in...more

3/20/2013 - Independent Contractors IRS Misclassification Payroll Taxes VCSP

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