Employment Tax


Chair: Edward J. Leyden, Leyden Law LLC, Washington, DC

IRS Employment Tax Update.
An overview of important developments since the Fall Meeting, including pertinent Supreme Court decisions, guidance projects in connection with the Tax Cut and Jobs Act, and proposed legislation.
Moderator: Prya C. Schwartzburt, PwC, Philadelphia, PA
Panelists: Janine Cook, Deputy Associate Chief Counsel, IRS Office of Chief Counsel (TEGE), Washington, DC (Invited); Sydney Gernstein, Branch Chief, Employment Tax Branch, IRS Office of Chief Counsel, Washington, DC (Invited)

IRC Section 409A: It’s Never Easy to Say Goodbye!
Since its enactment in 2004, IRC Section 409A has seemed like a minefield for lawyers advising companies and the executives who have come to the end of the line in their employment relationship. This program will attempt to dispel some of the mystery behind section 409A, enabling attorneys on both sides of an employment termination event to more confidently assess potential risks and rewards.
Moderator: Edward J. Leyden, Leyden Law LLC, Washington, DC
Panelists: Kurt Lawson, Hogan Lovell, Washington, DC

Creative Use of Federal Tax Statues as Enforcement Tools in Employment Controversies.
An emerging strategy being utilized by counsel for workers in employment controversies is the invocation of the federal tax laws as an affirmative weapon against employers that have been targeted for Wage & Hour and similar claims. This session will discuss the plaintiffs’ bar evolving use of this and other tax enforcement strategies in non-tax cases.
Moderator: Edward J. Leyden, Leyden Law LLC, Washington, DC
Panelists: Richard Neuworth, Lebeau & Neuworth, Towson, MD; Jay Holland, Joseph Greenwald & Laake, Greenbelt, MD

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