Comments on proposed QSLOB regulations under section 414(r).

Summary

---

Qualified separate lines of business

See the full content of this document

Extract

---

Comments on proposed QSLOB regulations under section 414(r).

On January 31, 1991, the Internal Revenue Service issued proposed regulations under section 414(r) of the Internal Revenue Code, providing the exclusive rules for determining whether an employer operates qualified separate lines of business. The proposed regulations (EE-147-87) were published in the Federal Register on February 1, 1991 (56 Fed. Re3g. 4023) and in the March 4, 1991, issue of the Internal Revenue Bulletin (1991-9 I.R.B. 15). A public hearing on the proposed regulations was held on May 16, 1991. (1)

BACKGROUND

Tax Executives Institute is the principal association of corporate tax executives in North America. Our nearly 4,700 members represent more than 2,000 of the leading corporations in the United States and Canada. TEI represents a cross-section of the business community, and is dedicated to the development and effective implementation of sound tax policy, to promote the uniform and equitable enforcement of tax laws, and to reduce the cost and burden of administration and compliance to the benefit of taxpayers and government alike. As a professional association, TEI is firmly committed to maintaining a tax system that works -- one that is administrable and with which taxpayers can comply.

Members of TEI are responsible for managing the tax affairs of their companies and must contend daily with the provisions of the tax law relating to the operation of business enterprises. We believe that the diversity and professional training of our members enable us to bring an important, balanced, and practical perspective to the issues raised by the separate line of business regulations.

OVERVIEW

The proposed qualified separate line of business (QSLOB) regulations are one of a series of regulatory projects interpreting the employee benefit provisions of the Tax Reform Act of 1986. Under sections 414(b) and 414(c) of the Internal Revenue Code, all employees of corporations that are members of the same controlled group of corporations and all employees of trades or businesses that are under common control are generally treated as employed by a single employer for purposes of the employee benefit provisions of the Code. Similarly, section 414(m) provides that all employees of members...

See the full content of this document

---