[4830-01-u]
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 31
[TD 8604]
RIN 1545-AS22
Liability of Third Parties Paying or Providing for Wages:
Suit Period and Its Extension and Maximum Amount
Recoverable.
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains final regulations regarding
the liability of lenders, sureties, or other third persons
for withholding taxes when those persons have supplied
funds, either directly to employees or to or for the account
of an employer, for the specific purpose of paying wages of
the employees of that employer. The final regulations affect
third parties paying or providing for wages.
EFFECTIVE DATE: August 1, 1995.
FOR FURTHER INFORMATION CONTACT: Robert A. Walker, (202)
622-3640 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
These final regulations contain changes to 31.3505-1.
Section 3505 of the Internal Revenue Code (Code) was added
by section 105(a) of the Federal Tax Lien Act of 1966, Pub.
L. 89-719 (1966). Treasury regulations were issued with an
effective date of August 19, 1976 (TD 7430). Neither the
Code section nor the regulations has been amended since
enactment or issuance, respectively. The IRS published a
notice of proposed rulemaking in the Federal Register on
November 22, 1994, (59 FR 60099) providing proposed rules
under section 3505 of the Code. No public comments were
received and accordingly, the final regulations are
identical to the proposed regulations.
Explanation of Provisions
Under section 3505(b), if a lender, surety, or other
person (the lender) supplies funds to or for the account of
an employer for the specific purpose of paying wages of the
employees of that employer, and the lender has actual notice
or knowledge (within the meaning of section 6323(i)(1)) that
the employer does not intend or will not be able to make
timely payment or deposit of the required withholding taxes,
the lender shall be liable to the United States in a sum
equal to the taxes (together with interest) that are not
paid over to the United States by the employer with respect
to those wages. The lender's liability for withholding
taxes, in lieu of the employer, is limited to an amount
equal to 25 percent of the amount of wages so supplied to or
for the account of the employer. See section 3505(b) (final
sentence).
Existing regulations provide that the 25-percent
limitation applies only to the tax, and not the interest on
that tax, with the result that the lender could be held
liable for more than 25 percent of the amount of funds it
supplied. The courts that have addressed this issue,
however, have held that the 25-percent limitation on the
amount of wages supplied by a third party is an absolute cap
with respect to the recovery of withholding taxes and
prejudgment interest. United States v. Metro Constr. Co.,
Inc., 602 F.2d 879 (9th Cir. 1979); United States v.
Intercontinental Ind., Inc., 635 F.2d 1215 (6th Cir. 1980);
United States v. Hannan Co., 639 F.2d 284 (5th Cir. 1981);
Taubman v. United States, 449 F. Supp. 520 (E.D. Mich.
1978). See also O'Hare v. United States, 878 F.2d 953 (6th
Cir. 1989); United States v. Security Pacific Business
Credit, Inc., 956 F.2d 703 (7th Cir. 1992); United States v.
Vaccarella, 735 F. Supp. 1421 (S.D. Ind. 1990).
These final regulations conform to judicial
interpretation and clarify that interest will continue to be
computed in addition to any withholding tax liability, but
only to an overall maximum of 25 percent of the amount of
the funds supplied by the lender.
The final regulations also change the period of
limitations for collection of the withholding taxes and
interest from six years to ten years. This revision will
conform the period of limitations for the purposes of
section 3505 with the general rule on limitations on
collection. See section 6502, amended by the Omnibus Budget
Reconciliation Act of 1990, Pub. L. 101-508, section
11317(a)(1) (1990).
Finally, 31.3505-1(d)(3) has been added to provide for
extensions of the period of limitation for collection
because, on occasion, the IRS or the lender requires
additional time for compliance with the regulation.
Special Analyses
It has been determined that this Treasury decision is
not a significant regulatory action as defined in EO 12866.
Therefore, a regulatory assessment is not required. It has
also been determined that section 553(b) of the
Administrative Procedure Act (5 U.S.C. chapter 5) and the
Regulatory Flexibility Act (5 U.S.C. chapter 6) do not apply
to these regulations, and, therefore, a Regulatory
Flexibility Analysis is not required. Pursuant to section
7805(f) of the Internal Revenue Code, the notice of proposed
rulemaking was submitted to the Chief Counsel for Advocacy
of the Small Business Administration for comment on its
impact on small business.
Drafting Information
The principal author of these final regulations is
Robert Walker, Office of Assistant Chief Counsel (General
Litigation). However, other personnel from the IRS and
Treasury Department participated in their development.
List of Subjects in 26 CFR Part 31
Employment taxes, Income taxes, Penalties, Pensions,
Railroad retirement, Reporting and recordkeeping
requirements, Social Security, Unemployment compensation.
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 31 is amended as follows:
Part 31--EMPLOYMENT TAXES
Paragraph 1. The authority citation for part 31
continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Paragraph 2. Section 31.3505-1 is amended by:
1. Removing the phrase "for such taxes" from the
second sentence of paragraph (b)(1).
2. Removing the phrase ", plus interest thereon" from
the final sentence of paragraph (b)(2), Example (1).
3. Removing the phrase "for withholding taxes" from
the fifth sentence of paragraph (b)(2), Example (2).
4. Removing the phrase "plus interest thereon" from
the final sentence of paragraph (b)(2), Example (2).
5. Revising the final sentence of paragraph (d)(1).
6. Revising the final sentence of paragraph
(d)(2)(iii).
7. Adding paragraphs (d)(3) and (g).
The additions and revisions read as follows:
31.3505-1 Liability of third parties paying or providing
for wages.
* * * * *
(d) * * *
(1) * * * In the event that the lender, surety, or
other person does not satisfy the liability imposed by
section 3505, the United States may collect the liability by
appropriate civil proceedings commenced within 10 years
after assessment of the tax against the employer.
* * * * *
(2) * * *
(iii) * * * Thus, after the second payment by the
employer, the lender's liability under section 3505(b) is
$75 ($250 less $175), plus interest due on the underpayment
for the period of underpayment, to a maximum of $250, 25
percent of the funds supplied.
(3) Extensions of the period for collection. Prior to
the expiration of the 10-year period for collection after
assessment against the employer, the lender, surety, or
other third party may agree in writing with the district
director, service center director, or compliance center
director to extend the 10-year period for collection. The
period so agreed upon may be extended by subsequent
agreements in writing made before the expiration of the
period previously agreed upon. If any timely proceeding in
court for the collection of the tax and any applicable
interest is commenced, the period during which such tax and
interest may be collected shall be extended and shall not
expire until the liability for the tax (or a judgment
against the lender, surety, or other third party arising
from such liability) is satisfied or becomes unenforceable.
* * * * *
(g) Effective date. These regulations are effective
on August 1, 1995.
Margaret Milner Richardson
Commissioner of Internal Revenue
Approved: June 21, 1995
Leslie Samuels
Assistant Secretary of the Treasury