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EIEIO
October 2nd, 2009, 07:15 PM
How to Avoid IRS Penalties with Correct Worker Classification

Business owners risk penalties imposed by the Internal Revenue Service if their workers are not correctly classified

by Clarice Tunison
October 2, 2009
HousingZone

Every kid knows the saying, “Sticks and stones will break my bones, but names will never hurt me.” On the playground, it’s true; but in the construction business, naming workers as employees or independent contractors must be done correctly, or business owners risk penalties imposed by the Internal Revenue Service. According to the Bureau of Labor Statistics, the construction industry has one of the highest instances of self-employed workers — more than 2 million people, or 20 percent of industry workers, label themselves independent contractors.

Classification differences are significant. Employees get a paycheck with certain taxes deducted, and a Form W‑2 at the end of the year; independent contractors get checks with no taxes deducted, and a Form 1099 that states how much they were paid for the year. Classifying workers as contractors saves money for employers, because businesses don’t incur payroll taxes — such as Social Security and unemployment insurance — and don’t pay for employee benefits or workers’ compensation insurance.

While the temptation may be great to save on those items, there are serious drawbacks for employers who incorrectly classify workers as independent contractors. In fact, the IRS penalties for misclassifying workers are significant.

Who’s in control here?

To satisfy the IRS, the key question is, to what extent does the business have the right to direct and control the worker? Construction managers generally have the right to control how employees perform their work, but independent contractors determine for themselves how the work is to be performed.

In deciding worker-classification cases, the courts have looked at facts in three main categories: behavioral control, financial control, and the relationship of the parties.

Behavioral control factors include any instructions that the employer gives the worker about when, where, and how to work; and any training the worker receives. Independent contractors ordinarily control their own work schedule and any necessary learning or training.

Financial control might include the extent of unreimbursed business expenses, which are likely to occur more often with independent contractors; how much the worker invests in facilities or equipment; and the extent to which the worker can realize a profit or incur a loss.

The relationship of employers and workers can be defined by contracts that are in place, and by whether the business provides the worker with employee-type benefits such as insurance, vacation pay, or a retirement plan.

Crime and punishment

The liability for an employer that unintentionally misclassifies an employee is limited to 1.5 percent of the employee’s wages for income tax withholding and 20 percent of the employee’s portion of FICA tax. However, intentionally misclassifying a worker exposes the employer to more severe measures. The range of disciplinary actions can include the full amount of income tax that should have been withheld, the full amount of the employer’s and employee’s FICA payments, interest and penalty amounts, and possible civil and criminal penalties, including jail time for the worst offenders.

To take the safest route, when in doubt, employers should classify workers as employees. If a worker is classified as an independent contractor, the hiring firm has the burden of proving that it had no control over the work or the worker. Use this form to determine worker status: http://www.irs.gov/pub/irs-pdf/fss8.pdf.

Government agencies can find other reasons to look at an employer’s classifying practices. When a former worker files an unemployment insurance claim, for example, an investigation is automatically triggered to determine the status of the employee.

Take the IRS test

The IRS uses a 20-factor test to determine proper classification, but also will look at written contracts for independent contractor classification. Contracts can include important language, stipulating that the independent contractor is not entitled to employee benefits programs, and acknowledging that the independent contractor is free to work elsewhere at any time.

Employers should not feel that they are secure simply because certain conditions exist. A hiring firm should not assume it is safe under any of these situations:

* The worker wanted to be treated as an independent contractor
* The worker signed a contract
* The worker does assignments sporadically, inconsistently, or is on call
* The worker is paid commission only
* The worker does assignments for more than one company.

Congress has established “safe-harbor,” or defense, provisions for employers that misclassify workers as independent contractors. An employer’s defense could be based on:

* Judicial precedent, published rulings, technical advice with respect to the taxpayer, or an IRS letter ruling to the taxpayer
* Past IRS audits, which applies only if there was no penalty assessment related to the treatment of individuals holding similar positions in the business
* Long-standing, recognized practice of a significant portion of the industry.

An employer may be denied the protection of safe harbor if it inconsistently classified workers who are doing the same tasks, or if the employer has not filed the appropriate tax forms consistent with the treatment of a worker as an independent contractor.

When business owners understand the rules and correctly classify their employees, they can save time and avoid penalties. Sticks and stones may not figure in the punishment, but the possibility of fines and jail time should be enough to get anyone’s attention.
Clarice Tunison is a Premier HR national Manager at the Sam Ramon, Calif. office of Paychex, Inc.

Link:http://www.housingzone.com/probuilder/article/CA6700053.html

Decoman
December 23rd, 2009, 08:37 AM
Good read.. and a lot of smaller shops really should read this. A lot of guys out there I assume are breaking most sub laws out there, including myself years ago back in the mid 90's when the laws were a little looser.

As a small shop my self you would be surprise how many guys say they "help me out" and just write me a check or even cash... If I think I need someone for a few weeks and there not a legit contractor that I can sub it to then your going on payroll...

Allrounder
December 23rd, 2009, 09:05 AM
The state of MN "helped" us this year by setting clear rules for who can and can't be classified as an independent contractor. Under the rules, subs need to be set up as an LLC or some sort of corporate entity and not just an individual proprietor.

Decoman
December 23rd, 2009, 09:26 AM
The state of MN "helped" us this year by setting clear rules for who can and can't be classified as an independent contractor. Under the rules, subs need to be set up as an LLC or some sort of corporate entity and not just an individual proprietor.

wow, thats pretty strict rule not that there's anything wrong with that..

Bodger
December 23rd, 2009, 10:31 AM
That IS strict. Most of my subs are sole proprietorship entities, not incorporated. But have DBAs and licenses and all that.

It's a slippery slope. I know one GC out here who is in the midst of an audit over this very issue. He is getting butt-stabbed by everyone. State, local and federal. Mainly because he employed guys full time, long term, and then did a 1099 on them.

You can really take a hit if you get snagged.

fez-head
December 23rd, 2009, 10:49 AM
the IRS paid a surprise visit to my office just last week..... I was scared as hell but the guy was actually pretty cool about everything and trying to set me up on a 3 year installment agreement to pay the back taxes.

I do have an IRS lien against all of my property but he said as long as i make the payments they will not seize anything. He also said that the IRS works with those that try to get back on track and then stay there. I've officially been "scared straight" now.

framer55
December 23rd, 2009, 01:29 PM
That IS strict. Most of my subs are sole proprietorship entities, not incorporated. But have DBAs and licenses and all that.

It's a slippery slope. I know one GC out here who is in the midst of an audit over this very issue. He is getting butt-stabbed by everyone. State, local and federal. Mainly because he employed guys full time, long term, and then did a 1099 on them.

You can really take a hit if you get snagged.

You can take a hit and if you are intentionally doing it, you should.

I have in the past and paid for my mistakes like Fez did.

Trust me, it is easier to run honest and ethically than to take short cuts!!

Bodger
December 23rd, 2009, 09:22 PM
You can take a hit and if you are intentionally doing it, you should.

I have in the past and paid for my mistakes like Fez did.

Trust me, it is easier to run honest and ethically than to take short cuts!!

the IRS paid a surprise visit to my office just last week..... I was scared as hell but the guy was actually pretty cool about everything and trying to set me up on a 3 year installment agreement to pay the back taxes.

I do have an IRS lien against all of my property but he said as long as i make the payments they will not seize anything. He also said that the IRS works with those that try to get back on track and then stay there. I've officially been "scared straight" now.


Yep. I owed the IRS $150K in back taxes and penalties at one time. I was sunk as far as I thought. Then I was able to do an Offer In Compromise and get back it in the system.

Took me five years to pay them off. I have been the model taxpayer ever since. They'll only give you that OIC once, then you're screwed.

I would sooner cross the Gambino family than mess with the IRS.

fez-head
December 23rd, 2009, 09:30 PM
Yep. I owed the IRS $150K in back taxes and penalties at one time. I was sunk as far as I thought. Then I was able to do an Offer In Compromise and get back it in the system.

Took me five years to pay them off. I have been the model taxpayer ever since. They'll only give you that OIC once, then you're screwed.

I would sooner cross the Gambino family than mess with the IRS.

150K! jesus and here I was scared sh!tless over 22K that I owe. Can't imagine what was going through your head when they "dropped in"

Bodger
December 23rd, 2009, 09:52 PM
150K! jesus and here I was scared sh!tless over 22K that I owe. Can't imagine what was going through your head when they "dropped in"



Oh man, like which method of offing myself would be the fastest and the most painless.

More than half of that was penalties and interest that had built up for years.
I was a stockbroker in the boom times of the 1980's and one of the firms I worked for was Drexel Burnham Lambert.

Some of the guys I knew at Drexel would have preferred to only have IRS problems compared to what they got nailed for.

Now, I am but a simple carpenter with a rehabilitated set of ethics.:angel:

EIEIO
December 23rd, 2009, 10:49 PM
I use to think the 3 scariest letters uttered was freeze DEA, till I heard We are from the IRS

Tommy
December 23rd, 2009, 10:57 PM
The state of MN "helped" us this year by setting clear rules for who can and can't be classified as an independent contractor. Under the rules, subs need to be set up as an LLC or some sort of corporate entity and not just an individual proprietor.

Subs can be a sole proprietor as long as they have an "Independant Contractor Exemption Certificate." w w w.dli.mn.gov/CCLD/ICEC.asp

Just the state trying to enforce the same rules as the IRS.

Bodger
December 24th, 2009, 12:29 AM
I use to think the 3 scariest letters uttered was freeze DEA, till I heard We are from the IRS


The IRS scares hell out of everyone. Even big time politicos.

My OIC took nearly two years to negotiate and finalize, and I had to appeal a couple of early decisions that were handed down that would have tanked me for life.
One thing I saw about the IRS is that the higher up the chain of command you go, the nicer and more professional the people are that you're dealing with. I figured it would be the opposite, and I had dealt with some real snarky dudes at first.
The final arbiter of my case even told me he respected the fact that I was a veteran, and while that didn't get me off the hook for my tax debt, it was something that was taken into consideration when he finalized my deal.

A lot of the lower level employees are refugees from layoffs at the lesser-honker agencies like the Department of Agriculture.

One woman told me, and I quote:
"Well, you just gots to pay like everybody else!!"

Decoman
December 24th, 2009, 07:10 AM
The IRS scares hell out of everyone. Even big time politicos.

My OIC took nearly two years to negotiate and finalize, and I had to appeal a couple of early decisions that were handed down that would have tanked me for life.
One thing I saw about the IRS is that the higher up the chain of command you go, the nicer and more professional the people are that you're dealing with. I figured it would be the opposite, and I had dealt with some real snarky dudes at first.
The final arbiter of my case even told me he respected the fact that I was a veteran, and while that didn't get me off the hook for my tax debt, it was something that was taken into consideration when he finalized my deal.

A lot of the lower level employees are refugees from layoffs at the lesser-honker agencies like the Department of Agriculture.

One woman told me, and I quote:
"Well, you just gots to pay like everybody else!!"


Did you tell her that goes for government employees too...

Allrounder
December 24th, 2009, 07:36 AM
Subs can be a sole proprietor as long as they have an "Independant Contractor Exemption Certificate." w w w.dli.mn.gov/CCLD/ICEC.asp

Just the state trying to enforce the same rules as the IRS.

Yep, you're right Tommy, but we have to withhold taxes with an ICEC, same as if they were an employee--too much of a PITA for me. Anybody who works for me has to be an LLC or corp and work as a sub.