This April 2013 webinar was developed for NRCPDS FMS Members at Boston College. The webinar focused on the proposed regulation, Section 3504-2. FMS expert Mollie Murphy explained in detail how the regulation suggests adding a part 2 to Section 3504, under which a payor, (a payor that would not normally be a Section 3504 Agent, such as an Agency in Agency with Choice) enters into a certain kind of “service agreement” to pay wages or compensation on behalf of an employer is considered to be designated as an agent of that employer, and would be held jointly liable with the employer for any employment taxes and penalties. All comments from the webinar were submitted to the IRS on behalf of membership.
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