Rev. Rul. 73-162
Rev. Rul. 73-162; 1973-1 C.B. 417
- Cross-Reference
26 CFR 31.3121(d)-2: Who are employers.
(Also Sections 1563, 3306, 3401; 1.1563-1, 31.3306(a)-1,
31.3401(d)-1.)
- LanguageEnglish
- Tax Analysts Electronic Citationnot available
The Internal Revenue Service has been asked whether the holdings in Revenue Ruling 69-316, 1969-1 C.B. 263, apply to brother-sister corporations as referred to in section 1563(a)(2), Internal Revenue Code of 1954.
Revenue Ruling 69-316 deals with whether a corporation, or its subsidiaries, or both, are the employers of certain individuals for purposes of the Federal Insurance Contributions Act, the Federal Unemployment Tax Act, and the Collection of Income Tax at Source on Wages (chapters 21, 23, and 24, subtitle C of the Code). The Revenue Ruling describes circumstances in which the individuals perform substantial services for a parent corporation, its subsidiaries, or both and are paid by the parent corporation.
Held, the holdings in Revenue Ruling 69-316 are applicable to brother-sister corporations in the same manner as they are to parent-subsidiary corporations.
Revenue Ruling 69-316 is amplified.
- Cross-Reference
26 CFR 31.3121(d)-2: Who are employers.
(Also Sections 1563, 3306, 3401; 1.1563-1, 31.3306(a)-1,
31.3401(d)-1.)
- LanguageEnglish
- Tax Analysts Electronic Citationnot available
