payroll reporting issues for government entities

Payroll Reporting Issues

for Government Entities

January 27, 2012

Certified Public Accountants & Business Advisors

© 2012 Sikich LLP. All rights reserved.

Recent Changes Common Errors Compensation/Worker Misclassification 1099 Reporting Issues Overview of Tax Advantaged Health Plans Taxability of Fringe Benefits

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Overview of topics covered



Payroll Tax Cut Temporarily Extended into 2012

Employee paid social security taxes will remain at 4.2% through February 29, 2012. 2% savings for employees continue.

Revised employment tax forms will be issued.



Temporary Payroll Tax Cut Continuation Act of 2011

The Act also provides for a “recapture” provision which applies to employees earning more than $18,350 in the first 2 months of 2012.

Imposes an additional income tax on these higher-income employees in an amount equal to 2% of wages received during the two months. (The social security wage base for 2012 is $110,100 and $18,350 represents two months of the full year amount).

Recapture tax will be paid by employee in 2013 when income tax return is filed. Additional information to be issued.



New Limits for 2012

Mileage rates for business travel• 2011 $.51 through 6/30/11• 2011 $.555 7/1/11 through 12/31/11• 2012 $.555 (no change from 2011 rate)



New Limits for 2012 (continued)

401(k) /403(b)/457(b) Plans• 2011 $16,500• 2012 $17,000

Catch up amounts• 2011 $5,500• 2012 $5,500

Eligible Compensation• 2011 $245,000• 2012 $250,000



New Limits for 2012 (continued)

Simple Plans• 2011 $11,500• 2012 $11,500

Catch up amounts (simple)• 2011 $2,500• 2012 $2,500



In order to exclude premiums from income the covered participant must be an employee or meet the definition of a dependent. • Domestic partners and civil unions do NOT

currently qualify as dependents• Imputed income must be calculated on any

employer provided premiums• Not eligible for pre-tax savings under Section

125 Plan if not a dependent

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Reporting and Taxability of Health Insurance



Taxation of Young Adult Dependent Coverage

Health Care Reform Act made change effective 3/30/10 that coverage to adult children who as of the end of the year have not turned age 27 will NOT result in imputed income to the employee.

Prior to 3/30/10 imputed income should be determined.

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Health Insurance coverage for Retirees

If coverage is provided to all retirees without an option to receive cash then coverage is not taxable

If employee could have received cash in lieu of the coverage then the coverage is taxable all in the year when the amount was available to them. The future years coverage will all be taxed earlier than when received. Revenue Ruling 75-539

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How to calculate the premium includable in gross income?

No formal IRS guidance is available PLR 9603011 and PLR 200339001 –

provide guidance for domestic partners and civil unions (non-dependents)

Both conclude “excess of the fair market value of the group medical coverage provided over the amount paid by the employee for such coverage is includible in gross income of the employee”

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How to calculate the premium includable in gross income?

Under Reg. Sec. 1.61-21(b)(2) fair market value is determined on the basis of the amount that an individual would have to pay for the particular fringe benefit in an arm’s-length transaction – the fair market value of the group medical coverage

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How do you determine fair market value?

Any reasonable method for calculating fair market value may be used:• Actuarial computation by insurance

provider• Greater of increase in incremental cost• COBRA premium for self-only coverage

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© 2012 Sikich LLP. All rights reserved.14

Health Insurance Reporting on Form W-2

Health Care Reform law added a requirement to report aggregate cost of employer provided health coverage.

Coverage does NOT become taxable, just for disclosure purposes and most likely to prepare for future years when excise taxes and mandatory coverage become effective.

IRS recently announced that this will NOT be required for 2011 to allow employers more time to prepare and receive additional IRS guidance.

The 2011 W-2 instructions list a code DD for Box 12 to report for those employers who elect to provide early.




Transition Rules:

• IRS announced that this will not be required until 2012 (reported in 2013) for large employers (250 or more employees)

• For small employers (less than 250 employees) until 2013 (2014 reporting).



• Additional Resources:• See Notices 2011-28 and 2012-9 for

most recent guidance• FAQ on IRS website under the ACA

pages of www.irs.gov or link: http://www.irs.gov/newsroom/article/0,,id=237894,00.html

• IRS presented webinar on topic see: http://www.irsvideos.gov/Webinars




Nondiscrimination Rules for Health Plans

Health Care Reform Act extended nondiscrimination rules to fully insured plans, previously only applied to self-insured plans.

If health plan does not retain grandfathered status need to ensure that employer provided coverage amounts do not discriminate in favor of higher paid employed.

Until guidance is issued IRS will not assess penalties. Watch for further developments in this area.



IRS Audit Activities

IRS is devoting a significant amount of its examination resources to the Employment Tax National Research Program (ETNRP).

ETNRP is a three year program to identify sources of under reported income and employment taxes or non-filing of required returns.

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ETNRP IRS will examine 500 governmental entities

selected at random.

First 90 entities were reviewed in 2010 and results should be issued shortly.

Second 180 entities were selected for review in 2011.

Additional 230 entities will be selected in 2012.

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ETNRP (Cont.d)

Includes review of:• Compliance with information return &

reporting requirements• Compliance with worker classification (i.e.

1099 or W-2 reporting)• Compliance with provisions of public

entity Section 218 agreements• Compliance with taxability of fringe

benefits

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Common Errors Noted by IRS with Payroll Reporting

Totals shown on Forms 941 do not reconcile with totals on Forms W-2 and W-3, or between these forms and accounting records.

Forms W-9 and W-4 are not being used or are not being updated when necessary.



Common Errors Noted by IRS with Payroll Reporting (cont.d)

Failure to backup withhold on payments to vendors when required.

Failure to correctly complete or file Forms 1099.

Failure to apply accountable plan rules to reimbursements and allowances.




Incorrect or missing employment tax deposits.

Failure to follow electronic filing requirements.

Treatment of certain groups of workers as independent contractors, rather than as employees.




Failure to include taxable noncash benefits in employee wages.

Failure to correctly apply withholding rules to election workers and public officials.

For public employers IRS now has self assessment checklist available on their website.



Perform Year-end Reconciliation Before Filing W-2’s and 941’s

The SSA will compare the 941 gross wage totals to Form W-3 totals for:

• Social Security and Medicare wages• Income tax withholding• Advanced earned income credit

Reconcile before you file to avoid notices




Generally your wages should reconcile as follows:

Box 1 wages on Form W-2

Plus employer pick-up amounts (govt employers)

Plus: 401(k), 403(b) and 457 contributions

Should equal Medicare and/or Social Security wages (W-2 boxes 3 and 5)




If wages on Forms W-2, W-3 and 941 do not match, you should determine that the reasons are valid and retain documentation in the event you are questioned by the IRS or SSA.



Form 1099-Misc Reporting

Originally included in Health Care Reform Act to include corporations in the requirements for 1099-Misc reporting

New rules have been repealed so corporations continue to be exempt from 1099-misc filing unless an exception applies such as:• Attorneys• Medical expenses



1099-Misc Issues

Make sure to obtain W-9 for all payments for services to ensure you have documentation of type of organization

Upon audit IRS will want to review and can impose penalties for failure to file 1099-Misc and require back up withholding at a rate of 28%

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1099-Misc Changes-1099-K Filing

2011 1099-Misc instructions state that payments made with a credit card must now be reported on 1099-K by the payment settlement entity.

Payments reported by the settlement entity are NOT required to be reported on form 1099-Misc reported by the payor

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Other 1099 topics Grant Payments

• Payments > $600 should be on 1099-G• Taxable unless excluded in federal legislation• Welfare type payments are often excluded• Inform recipient of 1099-G reporting upon issuance

of grant

Elected and Appointed Officials• Generally should be treated as employees not paid

on Form 1099 (per IRS Public Outreach guide page 6)



Information return penalties in 2011

The Small Business Jobs Protection Act (SBJA) substantially increases the penalties for failure to file correct and timely information returns and payee statements.

For example, previously penalty of $50/payee statement up to maximum of $100,000. New rules increase maximum to $1,500,000 plus inflationary adjustments.

Increased employment tax audits coupled with larger penalties create the “perfect storm” for employment tax audit assessments.



TIPRA 3% Withholding Repealed

The Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) added a provision to required entities making payments to a person providing property or services to deduct and withhold 3% tax from the payment. Set to become effective in 2013.

The Job Creation Act of 2011 repealed the TIPRA 3% withholding requirement.

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Payroll and Compensation Under Fire: What you Need to Know

Agencies (DOL, IRS) continue to focus on:

• Employee Classification

• Overtime Payment

• Independent Contractors

• Interns



FLSA Compliance

DOL has added new investigators for wage and hour

DOL is expected to be “very active”

DOL collections of back wages are up dramatically over the past decade

Class action cases have increased four fold since 1997



At least 75% of employers are not in compliance with the Fair Labor Standards Act – might actually be closer to 95%

FLSA Compliance



Employee Misclassification

U.S. Government Accountability Office reports there are at least 10 million workers in the U.S. who are classified as independent contractors

Labor Department estimates up to 30% of companies nationwide have misclassified employees



Employee Misclassification

Employers are liable for:• Payment of back taxes• Unpaid Social Security/Medicare

contributions• Unpaid unemployment insurance• Unpaid workers compensation

premiums• Penalties and interest



State Level Initiatives

11 states have signed on with the DOL

• Goal is to prevent, detect and remedy employee misclassification

• Illinois is one of the 11 states



DOL/IRS to Coordinate on Employee Misclassification

IRS and DOL sign Memorandum of Understanding

Result = increased number of employment tax audits = boost in compliance and increase in revenues



IRS Voluntary Classification Settlement Program

Initiative allows businesses to become compliant with worker classification requirements at significantly reduced penalty rates



IRS Voluntary Classification Settlement Program – Eligibility

Employer must have consistently treated a group of workers as non-employees in the past and filed appropriate 1099 forms for those workers during past 3 years

No current dispute between employer and IRS or applicable state agency

Going forward, employers must agree to treat as employees any workers they previously misclassified as independent contractors



IRS Voluntary Classification Settlement Program - Benefits

Employer will pay only 10% of employment tax liability

Employer is not required to pay interest or penalties

Employer will not be subject to employment tax audit regarding worker classification issues



IRS Voluntary Classification Settlement Program – Risks of not Participating

IRS can force non-compliant employers to pay the appropriate employment taxes in full for several years

Significant interest and monetary penalties



Participation in IRS Voluntary Settlement Program

Submit an application (Form 8952) to the IRS at least 60 days from the date on which employer wants to begin treating misclassified workers as employees



On February 15, 2012 1pm CST IRS is hosting a webinar on worker classification

Register at www.irs.gov and go to the governmental entities page

IRS Webinar



Why you Need to be Concerned

Fair Labor Standards Act

Illinois Minimum Wage Act

Illinois Wage Payment and Collection Act

Immigration Regulation and Control Act

Lilly Ledbetter Fair Pay Act



Exempt vs. Non-Exempt Hourly pay equals non-exempt

Responsibilities determine status

Title/payment type don’t determine status

Duties test

• Relative importance of exempt duties

• Amount of time spent performing exempt work

• Relative freedom from direct supervision



Independent Contractors

Tests for Independent contractors include:

• Behavioral control

• Financial control

• Type of relationship



Independent Contractors Make decisions re: how work is done

Not required to abide by organization’s policies/procedures

Can hire/fire their own employees

Do not work on the organization’s premises; make own schedules

Use own tools/equipment/materials

Engaged by many firms

Cannot be disciplined or dismissed

Paid per contractual arrangement



Unpaid Interns

Must be a structured educational experience

For the benefit of the intern

No promise of a job



Records Retention

At least three years• Payroll records• Collective bargaining agreements• Sales/purchase records

At least two years• Wage computation records

Records must be available for inspection



Four Most Common Mistakes

Failure to have a good system in place

Failure to properly record hours worked

Falling down on technical issues

Failure to calculate overtime properly



To Do List

Ensure you are following specific record keeping requirements for non-exempt employees

Have job descriptions for all positions for classification purposes

Have a process for classifying positions and follow it consistently

Maintain accurate pay records

Watch for improperly docked pay



To Do List

Make sure you are paying overtime correctly

Don’t allow non-exempt employees to work through lunch periods

Maintain all time records for NE employees

Have safe harbor policies in place



Tax Advantaged Health Plan Options

Flexible Spending Accounts-FSA’s

Health Reimbursement Accounts-HRA’s

Health Savings Accounts-HSA’s



Cafeteria Plans-FSA’s Pay for certain benefits pre-tax-typically EE paid

• Before FICA and Medicare• Before Federal and State taxes

Saves employer matching FICA taxes!

Not includible in compensation for IMRF (unless resolution adopted)

Benefits• Health, dental and other insurance premiums• Un-reimbursed medical expenses• Dependent care expenses



Cafeteria plan requirements

Must have WRITTEN PLAN DOCUMENT

Plan may need to be updated if amendments have not been made in several years.

IMRF amendment required to include contributions as IMRF eligible wages



Cafeteria plan changes Effective January 1, 2011

• Over-the-counter drugs are no longer qualified for purposes of the distributions/reimbursements under HSA’s, health FSA’s, and HRA’s, EXCEPT for prescription medicines and insulin. The new rules establish a more detailed and rigorous standard to qualify as a cafeteria plan.

Effective January 1, 2013• Contributions in a health FSA is limited to $2,500 per

year, indexed for inflation after 2013.



Health Reimbursement Accounts-HRA’s

Health Reimbursement Accounts-HRA’s• Employer Funded-NO EMPLOYEE

CONTRIBUTIONS• Can be funded or unfunded• Can choose to carryover unused amounts to

future years• Distributions are not taxable if used for

qualifying medical expenses



Health Savings Accounts

Health Savings Accounts-HSA’s• Employer OR Employee Funded• Must be funded• Unused amounts are carried over since it

if funded in individual accounts similar to IRA’s but for medical expenses

• Distributions are not taxable if used for qualifying medical expenses



HSA’s (Cont.d)

Must have high deductible health insurance plan• Minimum deductible of $1,200 for 2012 for individual

with out-of-pocket expenses of no more than $6,050 or $2,400 family deductible with total annual out-of-pocket expenses of no more than $12,100

Must not be covered by any other plans• Includes HRA and FSA with limited exceptions



HSA’s

Health Savings Accounts-HSA’s (Cont.d)• Allowable contributions up to $3,100 for 2012

or $6,250 for family regardless of policy deductible

Catch up contributions allowed for individuals age 55 or older-$1,000 for 2012



W-2 Reporting Flexible Spending Accounts-FSA’s

• Insurance premiums: not required to report on W-2 exclude from all boxes on W-2 (use code DD if electing to report early)

• Medical expenses: same as insurance premiums• Dependent Care: exclude from all taxable items on

W-2, however must also include in Box 10-dependent care benefits

o IRS uses this box to match up to amounts reported on Form 2441 on Form 1040



W-2 Reporting

Health Reimbursement Accounts-HRA’s• These are employer contributions and therefore

not reportable on Form W-2 • Think of as other employer paid insurance

premiums



W-2 Reporting Health Savings Accounts-HSA’s

• Employee contributionso Employee contributions are excluded from taxable

income box 1 and state income taxable wageso If the employer has a cafeteria plan which includes

these benefits then the employee contributions are also exempt from social security and Medicare.

o Report employee contributions in box 12 with a code W if paid through a cafeteria plan.

o Employees may also contribute on their own and report contributions on their 1040 to receive tax benefit.



W-2 Reporting

Health Savings Accounts-HSA’s• Employer contributions

o Employer contributions are excluded from all boxes on W-2

o Report employer contributions in box 12 with a code W.o IRS uses box 12 code W to calculate total allowable

contributions as reported on the individual’s 1040



Reporting of Fringe Benefits

Generally all amounts paid to employees are taxable• Federal and state income taxes• Employment taxes

Unless excludable under IRS code

Cash payments are taxable regardless of amount.



Checklist of Non-payroll Compensation

Advances Flat rate auto allowances Unsubstantiated business expense or in

excess of government approved limits Group term life insurance >$50,000 Disability pay-taxable portion Reimbursed employee moving

expenses



Checklist of Non-payroll Compensation

Personal use of company vehicle Cash achievement awards Compensation bonuses/Holiday bonuses Employer paid dues for country club or use

of athletic facilities or golf course• No additional cost services rules

Employer paid supplements to military pay Employees’ taxes paid by employer



Checklist of Non-payroll Compensation (cont.d)

Seasonal tickets to entertainment or sporting events for personal use.

Uniform allowances for uniforms that are (a) not required as a condition of employment or (b) street wearable.

Educational assistance over $5,250 unless qualifies as working condition fringe benefit.



Fringe Benefit Exclusions De Minimis Fringe

• Small value • Any cash paid is NOT de minimis and therefore taxable to the employee

Qualified Transportation Fringe• Pre-tax deductions available for: Commuter transportation, transit passes, and

qualified parking

Qualified Employee Discount

Working condition Fringe• Substantiated expenses• Use of property or service related to employer’s business

No Additional Cost Service



Examples of Working Condition Fringes

Job-related magazine subscriptions Professional dues Job-related education Business travel and entertainment Business use of company vehicle Employer provided retirement advice



No Additional Cost Services

IRS newsletter from 2004 addresses issues relating to taxation of employer provided:• Golf Courses• Athletic Centers• Park District Courses• Discounts on merchandise



No Additional Cost Services

Employee must be in the same line of business as the “free service”

In addition to there being no additional cost, there also must be no foregone revenue.

Employer should have policy to prevent any foregone revenue.



Employer Provided Vehicles

Personal use is taxable unless de minimis• Daily commuting is NOT de minimis

Exception for qualified non-personal use vehicle

• Defined in IRC Regulation 1.274-5T-Some examples:o Clearly marked police and fire vehicleso Unmarked vehicles used by law enforcement officers.

Officers must be authorized to carry a firearm, execute search warrants and make arrests.

• IRS FAQ on website states “ A police or fire vehicle is clearly marked if it has insignia or words which make it clear that it is a police or fire vehicle. A marking on a license plate is not a clear marking for this purpose.”




Final regulation issued 5/19/10

• Clearly marked police or fire officer vehicles are treated as qualified non-personal use vehicles if the following conditions apply:

o The employee must be on call at all times

o The employee must be required to use the vehicle for commuting

o The employer must prohibit personal use (other than commuting) for travel outside the officer’s or firefighter’s jurisdiction.




Final regulation issued 5/19/10:

• Adds “public safety officer vehicle” to the qualified non-personal use vehicle exclusion.

• A clearly marked public safety officer vehicle is a vehicle owned or leased by a governmental unit or any agency or instrumentality that is required to be used for commuting by a public safety officer.

• A public safety vehicle is “clearly marked” if, through painted insignia or words, it is readily apparent that the vehicle is a public safety officer vehicle.



Employer Provided Vehicles Final regulation issued 5/19/10:

• A public safety officer is an individual serving a public agency in an official capacity, with or without compensation, as a:

o Law enforcement officer, with power of arrest, authority to carry firearms, and execute search warrants.

o Firefightero Chaplain oro Member of rescue squad or ambulance crew.




Public Safety Officer (cont.d)• Any federal, state or local government public

safety officer who meets the on-call and commuting requirements above, and uses a clearly-marked government owned or leased vehicle in the course of his or her duties, is excepted from the substantiation requirements.




Three methods available to calculate personal use (IRS Publication 15-B, page 24 or Public Outreach guide page 8 & 9):• Automobile lease value• Commuting rule• Cents-per-mile rule



Car Allowances

Taxable unless accountable plan used

Accountable plan requires periodic reporting of expenses• Standard mileage rate or• Actual vehicle expenses

Allowance> actual expenses is either taxable or must be returned to employer



Employee Cell Phones IRS recently announced that if cell phones are

provided to employees for non compensatory business reasons it will not be taxable to the employee and detailed records no longer need to be maintained.

Examples of substantial business reasons:• Need to contact employee at all times for work-related

emergencies• Requirement that the employee be available to speak

with clients at times when the employee is away from the office.

• Need to speak with clients located in other time zones at times outside the employee’s normal work day.

See IRS Notice 2011-72



Uniforms and Work Clothes

Should be under an accountable plan

Clothing must be worn as a condition of employment.

Those clothes are not suitable for everyday wear.




Examples who may deduct cost: delivery workers, firefighters, health care workers, law enforcement officers, letter carriers, professional athletes, and transportation workers.

Clothing worn by plain clothes officers would not be deductible even if a result of a union negotiated contract.




Protective clothing: An employee can deduct the cost of protective clothing required in his/her work such as safety shoes or boots, safety glasses, hard hats, and work gloves.



Educational Programs

Job-related educational expenses are tax free to employee if:• Required by employer or law to maintain

current job skills• Maintains or improves skills required for

present work

Not tax-free if:• Education is needed to meet minimum job

requirements• Education qualifies employee for a new trade or

business



Educational Assistance Programs

Provides for tax free educational assistance up to $5,250/year.

Includes graduate courses. Must have written plan document. Must offer plan on nondiscriminatory

basis once written guidelines are established in document.



Group-Term Life Insurance Can exclude from income the cost up to $50,000 of group-

term life insurance

IRS determined cost for coverage in excess of $50,000 is includable as wages

IRS Pub 15-B includes the table to determine taxable income

Not subject to income tax withholding

Is subject to FICA and Medicare taxes



Taxability of Worker’s Compensation Benefits

Paid under worker’s comp law of state• Excludable from income, Social Security & Medicare

taxes

Paid “in the nature of” Worker’s Compensation Act• May be subject to employment taxes for the first 6

months • IRS Pub 15-A/IRS Federal State Guide Pub 963



Taxability of Worker’s Compensation Benefits

Disability retirement payments not in the line of duty are subject to the rules for federal income tax withholding from pension and annuities

Payments based on age of employee, length of service, or prior contributions are not payments in the nature of workers’ compensation.

These payments are reported on Form 1099-R.



Pick-Up Contribution Elections (Govt Employers)

Generally amounts withheld from employee paychecks need to be after tax unless there is an IRS code section allowing pre-tax treatment

For pension contributions, in order to be pre-tax the employer must elect to “pick-up” the contributions

The IRS provides in Section 414(h)(2) pretax pension contributions if certain conditions are met



Pick-Up Contribution Elections

In Revenue Ruling 2006-43 the IRS stated that in order for a contribution to a qualified plan to be treated as pick-up by the employer the following must occur:• The employer must take formal action to elect to

pick-up the contribution and the action must apply prospectively and be evidenced in writing, i.e., in a resolution, ordinance or minutes of a meeting

• The participant must not have the right to opt out of the “pick-up” or the right to receive the amounts directly in lieu of having them paid into the plan



Taxability of Pensions

The taxability of the pension depends on the source of the funds being contributed to the Fund

There are various types of contributions:• Employer contributions• Employee required contributions• Employee elected contributions for purchase of

prior service credit




Employer contributions-will be taxable to participant when pension received as employee did not pay tax on receipt of contribution

Employee required contributions• If pick-up contribution made, contributions were

made on a pretax basis so pension will be taxable upon receipt

• If no pick-up contribution made a portion of the pension will not be taxable as recovery of after tax contributions




Employee elected contributions for purchase of prior service credit• Revenue Ruling 2006-43 states that in order to qualify

as a pick-up contribution the arrangement must “not permit a participating employee from and after the date of the “pick-up” to have cash or deferred election right (within the meaning of Section 1.401(k)-1(a)(3)) with respect to designated employee contributions. Thus, for example, participating employees must not be permitted to opt out of the “pick-up,” or to receive the contributed amounts directly instead of having them paid by the employing unit to the plan.”




Employee elected contribution for purchase of prior service credit – source of funds:

• Payroll deductions - Rev Ruling 2006-43 any payroll deductions made to purchase prior service credits should be treated on a POST tax basis and basis should be tracked as with other after tax contributions to the Fund

• Rollover from a pretax account (such as IRA) - Contributions would be treated as pretax and amount taxable upon distribution




Employee elected contribution for purchase of prior service credit – source of funds (cont.d):• Lump sum payment - treated as post tax

payment and basis should be tracked and amount would not be taxable upon distribution



Useful References IRS website - www.irs.gov/govt

IRS Public Outreach Guide

IRS Pub 15-A-Employer’s Supplemental Tax Guide

IRS Pub 15-B-Employer’s Guide to Fringe Benefits

Taxable Fringe Benefit Guide-IRS website

IRS Pub 963- Joint Publication with Social Security



Useful References

www.dol.gov – Department of Labor Website

www.state.il.us/agency/idol/ - Illinois Department of Labor

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Contact Information:

Karen S. Sanchez, CPA, QPAPartner-in-ChargeHuman Resources and Employee Benefits 1415 W Diehl Road, Suite 400Naperville, IL 60563Phone (630) 566-8519Email: [email protected]