Roger Royse Law Blog

On September 27, 2010 the President signed the Small Business Jobs and Credit Act of 2010 (the “Act”) into law.  The Act provides for more than $40 billion worth of tax benefits aimed to support economic growth among small businesses.  In summary, the Act provides –

(1)     Increased deductions under Section 179 of the Internal Revenue Code (the “Code”).  In general, Code... Read More

I have always been impressed with the Swiss government’s longstanding capacity for discretion – much like the governmental equivalent of a friend that can keep a secret. Unfortunately, as we have been discovering, there are some very good reasons that Swiss account holders have demanded confidentiality, and Switzerland has finally had to cough up its secrets to the US government.

The IRS has had a two pronged approach to bringing foreign income back into the US tax net.... Read More

By now, everyone has heard of Section 409A of the Internal Revenue Code of 1986, as amended (the “Code”), which has turned traditional deferred compensation on its head by including deferrals in gross income unless they meet strict requirements.  While Hollywood may have been the furthest thing from Congress’s collective mind when Code Section 409A was enacted, its provisions are broad enough to reach common entertainment industry agreements. The basic problem is that... Read More

According to the recent decision in United States v. Quality Stores,

Inc., No. 1:09-cv-44 (W.D. Mich. Feb. 23, 2010) (”Quality Stores”),

severance payments resulting from an involuntary termination are not

subject to taxation under the Federal Insurance Contributions Act

(”FICA”) because such payments do not constitute “wages.” Prior to

Quality Stores, it was generally accepted that severance payments are

taxed like... Read More