THOMAS STOHLER

Expanding the definition of joint employer - On October 26, 2023, the National Labor Relations Board (NLRB) announced its final joint employer rule. The rule states that two or more entities may be considered joint employers of a group of employees if each entity has an employment relationship with the employees, and if the entities share or co-determine one or more of the employees essential terms and conditions of employment. The effective date of the new rule is February 26, 2024. The new standard will only be applied to cases filed after the effective date. that it would delay the effective date of the joint employer rule to February 26, 2024, in order to facilitate resolution of legal challenges with respect to the rule. The NLRB also clarified that the new standard will only be applied to cases filed after the rule becomes effective. NAPEO is opposed to this rule and supports legislation (H.J. Res. 98) which repeals the joint employer standard. E-Delivery - Each year, employers and health plans send more than a billion sheets of paper to Americas families regarding their health care benefits. Despite a strong preference for e-delivery health plan communications, federal law prohibits employers from defaulting to safe and secure electronic communications. Aligned with an overwhelming employee preference for e-delivery, recent federal rulemaking allowed for e-delivery in employee retirement plans. Extending greater flexibility for e-delivery in health benefit plans is a commonsense, straightforward regulatory action that would benefit the backbone of the economy - American workers, employers, and labor organizations - all while reducing the climate and environmental impacts of mandatory paper health care mailings.

Professional employer organizations (PEOs) provide payroll, employee benefits, and human resource services to more than 200,000 small and mid-sized businesses with 4 million employees nationwide. Small businesses contract with PEOs to provide these services, including the payment of wages to the employees and payment of the payroll taxes on those wages. PEOs are required under the licensing or registration laws of most states to report such wages under the Employer Identification Number (EIN) of the PEO. In addition, the Internal Revenue Code (IRC) requires CPEOs to report the wages under the CPEOs EIN accompanied by a schedule reporting wages on a client-by-client basis. The Employee Retention Tax Credit: Congress created the employee retention tax credit (ERTC) as part of the CARES Act to encourage businesses to keep employees on the payroll during the COVID-19 pandemic. The ERTC is a credit against payroll taxes that was initially made available with respect to wages paid by eligible employers after March 12, 2020 and before January 1, 2021. The Consolidated Appropriations Act, 2021 (CAA) retroactively made the ERTC available to many more small businesses by eliminating the prohibition on employers claiming the ERTC if they received a covered loan under the Paycheck Protection Program. Congress further expanded and extended the ERTC so that it was generally available for wages paid through September 30, 2021. In 2020, eligible employers could claim a maximum ERTC of $5,000 per employee. In 2021, the potential credit amount was increased significantly so that eligible employers could generally claim up to $7,000 per employee per quarter (for a per-employee maximum ERTC of $21,000 over Q1-Q3 2021). Apart from those limits, there was generally no aggregate cap on the amount of ERTC an eligible employer could claim. (Different rules applied for employers that met the definition of a recovery startup business.) Because the ERTC is a credit against payroll tax, it is claimed using the IRSs employment tax system. Instead of creating a separate tax form or process to help streamline ERTC claims, the IRS revised its existing employment tax returns (the quarterly-filed Form 941, for most employers), and required eligible employers to include any ERTC claims on their Form 941 for the applicable calendar quarter(s). Thus, an employer that was eligible to claim the ERTC for each quarter would have generally needed to claim the credit on six separate Forms 941 (Q2 2020 through Q3 2021). Because these claims are paper, and not electronic forms, there has been a processing backlog at the IRS. This backlog of unprocessed ERTC returns is more than one million. NAPEO is asking both Congress and the IRS to take action to eliminate this backlog. The backlog is harming small businesses that are entitled to this credit, and further delays may harm the ability of many small companies to continue operating. A second tax issue that NAPEO is working on - liability for payroll taxes claimed by the clients of PEOs. Congress continues to enact tax relief for small businesses by providing tax credits against the employers payroll tax liability. Examples include the research and development (R&D) payroll tax credit and the employee retention tax credit (ERTC). IRS procedures generally require that payroll tax credits be claimed on (or in connection with) the employers employment tax return. In the case of an employer whose employment taxes are reported on a PEOs aggregate Form 941 (referred to as a client employer), the only way for the client employer to claim a payroll tax credit is for the PEO to claim the credit on behalf of its client on the PEOs aggregate tax form (Form 941). When a PEO claims a payroll tax credit on behalf of a client employer, IRS procedures generally require the PEO to file Schedule R (Form 941) to provide client-level information regarding the client employers tax credit. A client employers eligibility for a payroll tax credit and the amount of the allowed credit is based on information that a PEO typically does not possess, such as a clients corporate tax return or quarterly gross receipts. Thus, to claim a payroll tax credit on behalf of its client, a PEO must rely on certain information provided by the client employer that in many cases the PEO is unable to verify. If it turns out that the credit was improperly claimed, it is unfair to hold the PEO liable if the client employer provides inaccurate information to the PEO. In addition, if the IRS subsequently examines a client employers payroll tax credit claim that was reported on a PEOs aggregate Form 941, this could negatively affect unrelated client employers by causing substantial delays in other clients receipt of payroll tax credits. An IRS examination of one clients payroll tax credit claim should not adversely affect other taxpayers. NAPEO is asking both the IRS and Congress to clarify and better define liability for payroll taxes filed by aggregate tax files, which includes PEOs and CPEOs. Given the increasing number of payroll tax credits targeted at small businesses - many of which depend on PEOs for payroll processing and reporting their employment taxes - it is critical that the tax code adequately address liability for improperly claimed credits on an aggregate tax return. NAPEO supports legislation that would: * Confirm that, with respect to any tax provision providing for an employer payroll tax credit, the client employer benefitting from the payroll tax credit is liable, and the PEO is not liable, for any improperly claimed credit amount, provided that the PEO reported the credit in accordance with information provided by the client. This would further clarify congressional intent in describing multiple payroll tax credits in Code section 3511(d)(2), which provides that client employers remain the taxpayer for purposes of such credits. * Ensure that any IRS examination or investigation of a client employers payroll tax credit claim that was reported on a PEOs aggregate employment tax return does not impact any other taxpayers, including with respect to delays in the processing or benefit of any payroll tax credits claimed by the PEO on behalf of other client employers. * Be business-model neutral with respect to entities that file aggregate employment tax returns , that is, available to PEOs, CPEOs, and agents under Code section 3504. We have also begun lobbying for tax reform, on the following issues: Liability for payroll tax claims made by the clients of PEOs; IRS examination or investigation of a client employers payroll tax credit claim that was reported on a PEOs aggregate employment tax return does not impact any other taxpayers; clarity that a PEO client can receive a Section 199A tax credit; and modernization of IRS tax return processing.

Expanding the definition of joint employer - On October 26, 2023, the National Labor Relations Board (NLRB) announced its final joint employer rule. The rule states that two or more entities may be considered joint employers of a group of employees if each entity has an employment relationship with the employees, and if the entities share or co-determine one or more of the employees essential terms and conditions of employment. The effective date of the new rule is February 26, 2024. The new standard will only be applied to cases filed after the effective date. that it would delay the effective date of the joint employer rule to February 26, 2024, in order to facilitate resolution of legal challenges with respect to the rule. The NLRB also clarified that the new standard will only be applied to cases filed after the rule becomes effective. NAPEO is opposed to this rule and supports legislation (H.J. Res. 98) which repeals the joint employer standard. E-Delivery - Each year, employers and health plans send more than a billion sheets of paper to Americas families regarding their health care benefits. Despite a strong preference for e-delivery health plan communications, federal law prohibits employers from defaulting to safe and secure electronic communications. Aligned with an overwhelming employee preference for e-delivery, recent federal rulemaking allowed for e-delivery in employee retirement plans. Extending greater flexibility for e-delivery in health benefit plans is a commonsense, straightforward regulatory action that would benefit the backbone of the economy - American workers, employers, and labor organizations - all while reducing the climate and environmental impacts of mandatory paper health care mailings.

Expanding the definition of joint employer - On October 26, 2023, the National Labor Relations Board (NLRB) announced its final joint employer rule. The rule states that two or more entities may be considered joint employers of a group of employees if each entity has an employment relationship with the employees, and if the entities share or co-determine one or more of the employees essential terms and conditions of employment. The effective date of the new rule is February 26, 2024. The new standard will only be applied to cases filed after the effective date. that it would delay the effective date of the joint employer rule to February 26, 2024, in order to facilitate resolution of legal challenges with respect to the rule. The NLRB also clarified that the new standard will only be applied to cases filed after the rule becomes effective. NAPEO is opposed to this rule and supports legislation (H.J. Res. 98) which repeals the joint employer standard

Expanding the definition of joint employer - On October 26, 2023, the National Labor Relations Board (NLRB) announced its final joint employer rule. The rule states that two or more entities may be considered joint employers of a group of employees if each entity has an employment relationship with the employees, and if the entities share or co-determine one or more of the employees essential terms and conditions of employment. The effective date of the new rule is February 26, 2024. The new standard will only be applied to cases filed after the effective date. that it would delay the effective date of the joint employer rule to February 26, 2024, in order to facilitate resolution of legal challenges with respect to the rule. The NLRB also clarified that the new standard will only be applied to cases filed after the rule becomes effective. NAPEO is opposed to this rule and supports legislation (H.J. Res. 98) which repeals the joint employer standard

Professional employer organizations (PEOs) provide payroll, employee benefits, and human resource services to more than 175,000 small and mid-sized businesses with 4 million employees nationwide. Small businesses contract with PEOs to provide these services, including the payment of wages to the employees and payment of the payroll taxes on those wages. PEOs are required under the licensing or registration laws of most states to report such wages under the Employer Identification Number (EIN) of the PEO. In addition, the Internal Revenue Code (IRC) requires CPEOs to report the wages under the CPEOs EIN accompanied by a schedule reporting wages on a client-by-client basis. The Employee Retention Tax Credit: Congress created the employee retention tax credit (ERTC). as part of the CARES Act to encourage businesses to keep employees on the payroll during the COVID-19 pandemic. The ERTC is a credit against payroll taxes that was initially made available with respect to wages paid by eligible employers after March 12, 2020 and before January 1, 2021. The Consolidated Appropriations Act, 2021 (CAA) retroactively made the ERTC available to many more small businesses by eliminating the prohibition on employers claiming the ERTC if they received a covered loan under the Paycheck Protection Program. Congress further expanded and extended the ERTC so that it was generally available for wages paid through September 30, 2021. In 2020, eligible employers could claim a maximum ERTC of $5,000 per employee. In 2021, the potential credit amount was increased significantly so that eligible employers could generally claim up to $7,000 per employee per quarter (for a per-employee maximum ERTC of $21,000 over Q1-Q3 2021). Apart from those limits, there was generally no aggregate cap on the amount of ERTC an eligible employer could claim. (Different rules applied for employers that met the definition of a recovery startup business.) Because the ERTC is a credit against payroll tax, it is claimed using the IRSs employment tax system. Instead of creating a separate tax form or process to help streamline ERTC claims, the IRS revised its existing employment tax returns (the quarterly-filed Form 941, for most employers), and required eligible employers to include any ERTC claims on their Form 941 for the applicable calendar quarter(s). Thus, an employer that was eligible to claim the ERTC for each quarter would have generally needed to claim the credit on six separate Forms 941 (Q2 2020 through Q3 2021). Because these claims are paper, and not electronic forms, there has been a processing backlog at the IRS. This backlog recently hit one million unprocessed Form 941-X (the form a small business would use to claim the ERTC). NAPEO is asking both Congress and the IRS to take action to eliminate this backlog. The backlog is harming small businesses that are entitled to this credit, and further delays may harm the ability of many small companies to continue operating. The backlog of applications for the ERTC hit one million in April 2023. A second tax issue that NAPEO is working on concerns liability for payroll taxes claimed by the clients of PEOs. Congress continues to enact tax relief for small businesses by providing tax credits against the employers payroll tax liability. Examples include the research and development (R&D) payroll tax credit and the employee retention tax credit (ERTC). IRS procedures generally require that payroll tax credits be claimed on (or in connection with) the employers employment tax return. In the case of an employer whose employment taxes are reported on a PEOs aggregate Form 941 (referred to as a client employer), the only way for the client employer to claim a payroll tax credit is for the PEO to claim the credit on behalf of its client on the PEOs aggregate tax form (Form 941). When a PEO claims a payroll tax credit on behalf of a client employer, IRS procedures generally require the PEO to file Schedule R (Form 941) to provide client-level information regarding the client employers tax credit. A client employers eligibility for a payroll tax credit and the amount of the allowed credit is based on information that a PEO typically does not possess, such as a clients corporate tax return or quarterly gross receipts. Thus, to claim a payroll tax credit on behalf of its client, a PEO must rely on certain information provided by the client employer that in many cases the PEO is unable to verify. If it turns out that the credit was improperly claimed, it is unfair to hold the PEO liable if the client employer provides inaccurate information to the PEO. In addition, if the IRS subsequently examines a client employers payroll tax credit claim that was reported on a PEOs aggregate Form 941, this could negatively affect unrelated client employers by causing substantial delays in other clients receipt of payroll tax credits. An IRS examination of one clients payroll tax credit claim should not adversely affect other taxpayers. NAPEO is asking both the IRS and Congress to clarify and better define liability for payroll taxes filed by aggregate tax files, which includes PEOs and CPEOs. Given the increasing number of payroll tax credits targeted at small businesses - many of which depend on PEOs for payroll processing and reporting their employment taxes - it is critical that the Code adequately address liability for improperly claimed credits on an aggregate tax return. NAPEO supports legislation that would: * Confirm that, with respect to any tax provision providing for an employer payroll tax credit, the client employer benefitting from the payroll tax credit is liable, and the PEO is not liable, for any improperly claimed credit amount, provided that the PEO reported the credit in accordance with information provided by the client. This would further clarify congressional intent in describing multiple payroll tax credits in Code section 3511(d)(2), which provides that client employers remain the taxpayer for purposes of such credits. * Ensure that any IRS examination or investigation of a client employers payroll tax credit claim that was reported on a PEOs aggregate employment tax return does not impact any other taxpayers, including with respect to delays in the processing or benefit of any payroll tax credits claimed by the PEO on behalf of other client employers. * Be business-model neutral with respect to entities that file aggregate employment tax returns , that is, available to PEOs, CPEOs, and agents under Code section 3504. Finally, NAPEO continues to work with the IRS to improve the process by which a PEO can be certified by the IRS (The CPEO program). Items we support include making permanent the electronic signature on IRS Form 8973; the electronic filing of Form 8973; and improved/more transparent procedures for the CPEO suspension and termination process.

SECURE 2.0 is a comprehensive retirement plan reform bill enacted as part of the 2022 year-end spending bill. The bill has nearly 100 provisions making (mostly) improvements to 401(k) plans, IRAs, and other tax-advantaged savings vehicles. Broadly speaking, the goals of the bill are: Encourage more employers to offer their employees a retirement plan at work-something PEOs do really well. Encourage employees to save more for their future and to preserve those savings for longer in retirement. Simplify and streamline the complex rules that apply to 401(k) and similar plans. Again, reducing all the complexity out of offering benefits like a 401(k) plan is something PEOs have done from the very beginning. NAPEO supports there being a delay in the Roth catch-up provision of SECURE 2.0., in order to give providers and their software support teams/companies time to implement the requirements of this provision. NAPEO has signed onto letters written by other organizations asking Congress and Treasury to delay the implementation of this provision.

Professional employer organizations (PEOs) provide payroll, employee benefits, and human resource services to more than 175,000 small and mid-sized businesses with 4 million employees nationwide. Small businesses contract with PEOs to provide these services, including the payment of wages to the employees and payment of the payroll taxes on those wages. PEOs are required under the licensing or registration laws of most states to report such wages under the Employer Identification Number (EIN) of the PEO. In addition, the Internal Revenue Code (IRC) requires CPEOs to report the wages under the CPEOs EIN accompanied by a schedule reporting wages on a client-by-client basis. The Employee Retention Tax Credit: Congress created the employee retention tax credit (ERTC). as part of the CARES Act to encourage businesses to keep employees on the payroll during the COVID-19 pandemic. The ERTC is a credit against payroll taxes that was initially made available with respect to wages paid by eligible employers after March 12, 2020 and before January 1, 2021. The Consolidated Appropriations Act, 2021 (CAA) retroactively made the ERTC available to many more small businesses by eliminating the prohibition on employers claiming the ERTC if they received a covered loan under the Paycheck Protection Program. Congress further expanded and extended the ERTC so that it was generally available for wages paid through September 30, 2021. In 2020, eligible employers could claim a maximum ERTC of $5,000 per employee. In 2021, the potential credit amount was increased significantly so that eligible employers could generally claim up to $7,000 per employee per quarter (for a per-employee maximum ERTC of $21,000 over Q1-Q3 2021). Apart from those limits, there was generally no aggregate cap on the amount of ERTC an eligible employer could claim. (Different rules applied for employers that met the definition of a recovery startup business.) Because the ERTC is a credit against payroll tax, it is claimed using the IRSs employment tax system. Instead of creating a separate tax form or process to help streamline ERTC claims, the IRS revised its existing employment tax returns (the quarterly-filed Form 941, for most employers), and required eligible employers to include any ERTC claims on their Form 941 for the applicable calendar quarter(s). Thus, an employer that was eligible to claim the ERTC for each quarter would have generally needed to claim the credit on six separate Forms 941 (Q2 2020 through Q3 2021). Because these claims are paper, and not electronic forms, there has been a processing backlog at the IRS. This backlog recently hit one million unprocessed Form 941-X (the form a small business would use to claim the ERTC). NAPEO is asking both Congress and the IRS to take action to eliminate this backlog. The backlog is harming small businesses that are entitled to this credit, and further delays may harm the ability of many small companies to continue operating. A second tax issue that NAPEO is working on concerns liability for payroll taxes claimed by the clients of PEOs. Congress continues to enact tax relief for small businesses by providing tax credits against the employers payroll tax liability. Examples include the research and development (R&D) payroll tax credit and the employee retention tax credit (ERTC). IRS procedures generally require that payroll tax credits be claimed on (or in connection with) the employers employment tax return. In the case of an employer whose employment taxes are reported on a PEOs aggregate Form 941 (referred to as a client employer), the only way for the client employer to claim a payroll tax credit is for the PEO to claim the credit on behalf of its client on the PEOs aggregate tax form (Form 941). When a PEO claims a payroll tax credit on behalf of a client employer, IRS procedures generally require the PEO to file Schedule R (Form 941) to provide client-level information regarding the client employers tax credit. A client employers eligibility for a payroll tax credit and the amount of the allowed credit is based on information that a PEO typically does not possess, such as a clients corporate tax return or quarterly gross receipts. Thus, to claim a payroll tax credit on behalf of its client, a PEO must rely on certain information provided by the client employer that in many cases the PEO is unable to verify. If it turns out that the credit was improperly claimed, it is unfair to hold the PEO liable if the client employer provides inaccurate information to the PEO. In addition, if the IRS subsequently examines a client employers payroll tax credit claim that was reported on a PEOs aggregate Form 941, this could negatively affect unrelated client employers by causing substantial delays in other clients receipt of payroll tax credits. An IRS examination of one clients payroll tax credit claim should not adversely affect other taxpayers. NAPEO is asking both the IRS and Congress to clarify and better define liability for payroll taxes filed by aggregate tax files, which includes PEOs and CPEOs. Given the increasing number of payroll tax credits targeted at small businesses - many of which depend on PEOs for payroll processing and reporting their employment taxes - it is critical that the Code adequately address liability for improperly claimed credits on an aggregate tax return. NAPEO supports legislation that would: * Confirm that, with respect to any tax provision providing for an employer payroll tax credit, the client employer benefitting from the payroll tax credit is liable, and the PEO is not liable, for any improperly claimed credit amount, provided that the PEO reported the credit in accordance with information provided by the client. This would further clarify congressional intent in describing multiple payroll tax credits in Code section 3511(d)(2), which provides that client employers remain the taxpayer for purposes of such credits. * Ensure that any IRS examination or investigation of a client employers payroll tax credit claim that was reported on a PEOs aggregate employment tax return does not impact any other taxpayers, including with respect to delays in the processing or benefit of any payroll tax credits claimed by the PEO on behalf of other client employers. * Be business-model neutral with respect to entities that file aggregate employment tax returns , that is, available to PEOs, CPEOs, and agents under Code section 3504. Finally, NAPEO continues to work with the IRS to improve the process by which a PEO can be certified by the IRS (The CPEO program). Items we support include making permanent the electronic signature on IRS Form 8973; the electronic filing of Form 8973; and improved/more transparent procedures for the CPEO suspension and termination process.

NAPEO is asking Congress to amend the federal tax code to clarify that liability for incorrectly or falsely taking this credit rests with the client of a PEO. In addition, NAPEO has asked the Dept. of Treasury and the IRS to ensure that enforcement against incorrect or false claims of tax credits, specifically the R&D Tax Credit, focuses on the entity that claimed the credit. NAPEO is asking Congress for broad liability protection for PEOs - which file payroll taxes on behalf of their small business clients - on all payroll tax credits taken by PEO clients. Mistakes or fraudulent claims made by PEO clients should be the responsibility of the client. NAPEO continues to ask the IRS to simplify the process of filing the ERTC for PEO small business clients, to make these processes electronic where possible, and to set up additional procedures to help PEOs track their Form 941 tax filings as well as the Form 941-X filings made on behalf of a PEO small business client. In addition, NAPEO has asked the IRS to create a "1-800" number for PEOs to call to obtain information on their small business client's ERTC claims; to create a group within the Service to process/handle PEO 941 and 941X filings; and for the IRS to put into place procedures that ensure that proper credits taken by PEO clients are provided in full to those clients.

NAPEO is asking Congress to amend the federal tax code to clarify that liability for incorrectly or falsely taking this credit rests with the client of a PEO. In addition, NAPEO has asked the Dept. of Treasury and the IRS to ensure that enforcement against incorrect or false claims of tax credits, specifically the R&D Tax Credit, focuses on the entity that claimed the credit. NAPEO is asking Congress for broad liability protection for PEOs - which file payroll taxes on behalf of their small business clients - on all payroll tax credits taken by PEO clients. Mistakes or fraudulent claims made by PEO clients should be the responsibility of the client. NAPEO continues to ask the IRS to simplify the process of filing the ERTC for PEO small business clients, to make these processes electronic where possible, and to set up additional procedures to help PEOs track their Form 941 tax filings as well as the Form 941-X filings made on behalf of a PEO small business client. In addition, NAPEO has asked the IRS to create a "1-800" number for PEOs to call to obtain information on their small business client's ERTC claims; to create a group within the Service to process/handle PEO 941 and 941X filings; and for the IRS to put into place procedures that ensure that proper credits taken by PEO clients are provided in full to those clients.

NAPEO is asking Congress to amend the R&D tax credit to clarify that liability for incorrectly or falsely taking this credit rests with the client of a PEO. In addition, NAPEO has asked the Dept. of Treasury and the IRS to ensure that enforcement against incorrect or false claims of the R&D tax credit focuses on the entity that claimed the credit. NAPEO is asking Congress for broad liability protection for PEOs - which file payroll taxes on behalf of their small business clients - on all payroll tax credits taken by PEO clients. Mistakes or fraudulent claims made by PEO clients should be the responsibility of the client. NAPEO continues to ask the IRS to simplify the process of filing the ERTC for PEO small business clients, to make these processes electronic where possible, and to set up additional procedures to help PEOs track their Form 941 tax filings as well as the Form 941-X filings made on behalf of a PEO small business client. In addition, NAPEO has asked the IRS to create a "1-800" number for PEOs to call to obtain information on their small business client's ERTC claims; to create a group within the Service to process/handle PEO 941 and 941X filings; and for the IRS to put into place procedures that ensure that proper credits taken by PEO clients are provided in full to those clients. PEO client deferral of payroll taxes/repayment of deferred taxes: Section 2302 of the CARES Act allowed employers to defer the deposit and payment of the employer's share of Social Security taxes for the period of March 27, 2020, through December 31, 2020. Employers must pay 50% of the deferred amount by December 31, 2021, and the remaining portion by December 31, 2022, to avoid penalties and interest. Importantly, the CARES Act provides that, if an employer directs a PEO to defer the payment of the employers share of Social Security taxes during the deferral period, then such employer shall be solely liable for the payment of deferred amounts by the applicable due dates. The IRS has may not have the resources to timely match all repayments of deferred amounts against the amount of the deferral liability at the client employer level as reported on the Schedule R. As a result of this limitation, the IRS is planning to rely on the PEO to help reconcile repayments and to assist the IRS in eventually transferring what has initially been recorded by the IRS as a PEO tax liability to the appropriate client employers accounts. This policy has raised a variety of concerns for the PEO industry, including - * PEOs generally lack information regarding (1) client employers that made repayments outside of the PEO relationship, and the amount of such payment, and (2) client employers that failed to repay a deferred amount when due. * Many employers (PEO clients) whose deferrals were reported by a PEO on Schedule R may no longer be a client of that PEO, and some may have gone out of business. Others may have entered a service contract with a different PEO. Once a PEO contract is terminated, the former client employer is much less likely to provide their deferred amount to the PEO for payment to the IRS or even to inform the PEO that the employer submitted payment itself directly to the IRS. NAPEO is working with the IRS to address these concerns and address the problems this approach raises.

Form EEO-1: The Equal Employment Opportunity Commission changed the filing process for PEO clients that are required to file a Form EE0-1 (businesses with 100 or more employees; federal contractors with 50 or more employees). The announced changes were unexpected, and the time to comply with the new filing requirements was considered inadequate by many NAPEO members. NAPEO asked the EEOC to provide more detail on the filing requirements and ask the agency to delay the filing deadline fore up to a year so PEOs could convert their electronic filing systems to the new processes.

NAPEO is asking Congress to amend the R&D tax credit to clarify that liability for incorrectly or falsely taking this credit rests with the client of a PEO. In addition, NAPEO has asked the Dept. of Treasury and the IRS to ensure that enforcement against incorrect or false claims of the R&D tax credit focuses on the entity that claimed the credit. NAPEO continues to ask the IRS to simplify the process of filing the ERTC for PEO small business clients, to make these processes electronic where possible, and to set up additional procedures to help PEOs track their Form 941 tax filings as well as the Form 941-X filings made on behalf of a PEO small business client. PEO client deferral of payroll taxes/repayment of deferred taxes: Section 2302 of the CARES Act allowed employers to defer the deposit and payment of the employer's share of Social Security taxes for the period of March 27, 2020, through December 31, 2020. Employers must pay 50% of the deferred amount by December 31, 2021, and the remaining portion by December 31, 2022, to avoid penalties and interest. Importantly, the CARES Act provides that, if an employer directs a PEO to defer the payment of the employers share of Social Security taxes during the deferral period, then such employer shall be solely liable for the payment of deferred amounts by the applicable due dates. The IRS has may not have the resources to timely match all repayments of deferred amounts against the amount of the deferral liability at the client employer level as reported on the Schedule R. As a result of this limitation, the IRS is planning to rely on the PEO to help reconcile repayments and to assist the IRS in eventually transferring what has initially been recorded by the IRS as a PEO tax liability to the appropriate client employers accounts. This policy has raised a variety of concerns for the PEO industry, including - * PEOs generally lack information regarding (1) client employers that made repayments outside of the PEO relationship, and the amount of such payment, and (2) client employers that failed to repay a deferred amount when due. * Many employers (PEO clients) whose deferrals were reported by a PEO on Schedule R may no longer be a client of that PEO, and some may have gone out of business. Others may have entered a service contract with a different PEO. Once a PEO contract is terminated, the former client employer is much less likely to provide their deferred amount to the PEO for payment to the IRS or even to inform the PEO that the employer submitted payment itself directly to the IRS. NAPEO is working with the IRS to address these concerns and address the problems this approach raises.

NAPEO is asking Congress to amend the R&D tax credit to clarify that liability for incorrectly or falsely taking this credit rests with the client of a PEO. In addition, NAPEO has asked the Dept. of Treasury and the IRS to ensure that enforcement against incorrect or false claims of the R&D tax credit focuses on the entity that claimed the credit. Specifically, NAPEO has asked to have language added to S. 749, the American Innovation and Jobs Act that would clarify the liability for the R&D tax credit for third party tax entities such as PEOs. Certified PEO Program: NAPEO asked the IRS to permanently allow certified PEOs to use electronic signatures on IRS Form 8973; to clarify the suspension and revocation process in the CPEO program; and to simplify the process of filing the ERTC - and make these processes electronic where possible. PEO client deferral of payroll taxes/repayment of deferred taxes: Section 2302 of the CARES Act allowed employers to defer the deposit and payment of the employer's share of Social Security taxes for the period of March 27, 2020, through December 31, 2020. Employers must pay 50% of the deferred amount by December 31, 2021, and the remaining portion by December 31, 2022, to avoid penalties and interest. Importantly, the CARES Act provides that, if an employer directs a PEO to defer the payment of the employers share of Social Security taxes during the deferral period, then such employer shall be solely liable for the payment of deferred amounts by the applicable due dates. The IRS has may not have the resources to timely match all repayments of deferred amounts against the amount of the deferral liability at the client employer level as reported on the Schedule R. As a result of this limitation, the IRS is planning to rely on the PEO to help reconcile repayments and to assist the IRS in eventually transferring what has initially been recorded by the IRS as a PEO tax liability to the appropriate client employers accounts. This policy has raised a variety of concerns for the PEO industry, including - * PEOs generally lack information regarding (1) client employers that made repayments outside of the PEO relationship, and the amount of such payment, and (2) client employers that failed to repay a deferred amount when due. * Many employers (PEO clients) whose deferrals were reported by a PEO on Schedule R may no longer be a client of that PEO, and some may have gone out of business. Others may have entered a service contract with a different PEO. Once a PEO contract is terminated, the former client employer is much less likely to provide their deferred amount to the PEO for payment to the IRS or even to inform the PEO that the employer submitted payment itself directly to the IRS. NAPEO is working with the IRS to address these concerns and address the problems this approach raises.

On September 14, the Department of Labor, Internal Revenue Service, and Pension Benefit Guaranty Corporation issued a Notice of proposed forms revision and DOL issued a proposed rule relating to benefit plan reporting. The proposed rule focuses on changes to the Form 5500 to reflect statutory changes made by the SECURE Act. Many of these changes will be significant for PEO-sponsored retirement plans. In particular, the Proposed Rule that may impact PEO-sponsored health and welfare plans. Under the Proposed Rule, a PEO filing an M-1 would have to begin publicly disclosing its clients that participate in the plan in that filing. NAPEO is opposed to PEOs being forced to disclose their client lists on the DOL website. Moreover, this requirement goes against Congressional intent and could facilitate cyber crime against PEO clients. NAPEO has filed comments against this proposed rule and may take additional action to prevent their implementation.

EEOC/EEO-1 Forms: NAPEO is asking the Equal Employment Opportunity Commission to clarify that the clients of PEOs who meet the requirements of filing a Form EEO-1 are ultimately responsible for filing this form.

Employee Retention Tax Credit (ERTC): NAPEO asked Congress, the Treasury, and the IRS to extend special reporting rules for the ERTC contained in the Consolidated Appropriations Act (CAA) to allow employers the option to claim the ERTC with respect to qualified wages paid in 2020 or 2021 on their future payroll tax returns, without the need to file amended returns for each quarter. In addition, NAPEO asked the IRS and Treasury to allow for retroactive ERTC claims from 2020 to be taken on 2021 quarterly tax returns. Finally, NAPEO asked Treasury/IRS to create a special post box for ERTC 941-X filings, to help expedite the processing of these tax returns. NAPEO is asking Congress to amend the R&D tax credit to clarify that liability for incorrectly or falsely taking this credit rests with the client of a PEO. In addition, NAPEO has asked the Dept. of Treasury and the IRS to ensure that enforcement against incorrect or false claims of the R&D tax credit focuses on the entity that claimed the credit. Specifically, NAPEO has asked to have language added to S. 749, the American Innovation and Jobs Act that would clarify the liability for the R&D tax credit for third party tax entities such as PEOs. Certified PEO Program: NAPEO asked the IRS to permanently allow certified PEOs to use electronic signatures on IRS Form 8973; to clarify the suspension and revocation process in the CPEO program; and to simplify the process of filing the ERTC - and make these processes electronic where possible.

Employee Retention Tax Credit (ERTC): NAPEO asked Congress, the Treasury, and the IRS to extend special reporting rules for the ERTC contained in the Consolidated Appropriations Act (CAA) to allow employers the option to claim the ERTC with respect to qualified wages paid in 2020 or 2021 on their future payroll tax returns, without the need to file amended returns for each quarter. In addition, NAPEO asked the IRS and Treasury to allow for retroactive ERTC claims from 2020 to be taken on 2021 quarterly tax returns. Finally, NAPEO asked Treasury/IRS to create a special post box for ERTC 941-X filings, to help expedite the processing of these tax returns.

COBRA/The American Rescue Act: NAPEO lobbied Congress to clarify language in the American Rescue Act related to tax credits given for COBRA subsidization to third party payors (including professional employer organizations, certified professional employer organizations, or agents under section 3504 of the Internal Revenue Code. NAPEO asked for language to ensure third-party payors can retain the aggregate amount of the tax credits where the third-party payor is remitting the COBRA premium (net of the subsidy) to carriers for its clients.

Payroll Protection Plan Loans: NAPEO lobbied Congress on the following legislation - H.R. 7777/S. 4117: to forgive all PPP loans of $150,000 or less; H.R. 6800 (HEROs ACT)/H.R. 6697, The Local Chamber, Tourism, and 501(c)(6) Protection Act of 2020 - provision in HEROs Act that would allow 501(c)(6) organizations to be eligible for PPP loans/H.R. 6697 would do the same; H.R. 8265 which would amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program; and Asked the Small Business Administration to reinforce its regulations and guidance stating that a 941 was not necessary for a small business to apply for and obtain PPP Loan forgiveness and that a statement from a 3rd party payroll provider was sufficient.

NAPEO asked the IRS to allow Certified PEOS to obtain electronic signatures from their CPEO clients for Form 8973. Currently, CPEOs must obtain a "wet signature" for this mandatory IRS form.

NAPEO lobbied in support of the following COVID-19 liability reform bills - S. 4317, The Safe To Work Act, which would discourage insubstantial lawsuits relating to COVID-19 while preserving the ability of individuals and businesses that have suffered real injury to obtain complete relief. H.R. 7528, The Get America Back to Work Act, which would limit the civil liability of persons for the spread or possible transmission of SARS-COV-2 caused by an act or omission while acting in good faith during the COVID-19 emergency period.

Ask Congress to provide unemployment tax relief from the dramatic increases in unemployment taxes and costs to employers due to unemployment compensation paid because of the COVID-19 shut downs. Specifically: 1. Provide for a transfer of federal funds to state UI trust funds equal to the amount of benefits paid due to COVID 2. Extend the Title XII interest waiver through 2021 3. Delay the application of the FUTA offset credit reduction for a year 4. Provide short-term transfers of federal funds to state UI trust fund accounts under Section 2103 of the CARES Act (increase the 50% to 100%) specifically to reduce the charges to reimbursing employers due to the COVID-19 recession.

Payroll Protection Plan Loans: NAPEO lobbied Congress and the Administration for the following - * To make sure that PEO client employees were not consolidated with other PEO clients and made ineligible for PPP loans. * To make sure that PEO clients were not required to use Form 941 to prove payroll when applying for PPP loans; and to make sure that PEO representation of client payroll was sufficient for a small business to qualify for a PPP loan. * In support of HR 7100 the Paycheck Protection Flexibility Act - in particular the the repeal the 75%/25% rule; extending the eight-week period for purposes of calculating PPP loan forgiveness; and ensuring full access to payroll tax deferment for businesses that take PPP loans. * In support of additional funding for the PPP loan program.

NAPEO lobbied the following tax issues related to the CARES Act * The option for a PEO to support the FFCRA paid leave credits and CARES employee retention credits for specific client employers out of the PEO's aggregate employment tax payments as reported on IRS Form 941. * An extension for the filing of PEO Q2 941/Schedule R tax filings due to the difficulty of complying with/reconciling PEO client IRS Form 7200 on payroll tax filings. * Guidance that confirms that PEOs may rely on the representations of a client in connection with granting the client (1) access to the credits and deferrals against employment taxes with respect to wages paid by the PEO to employees performing service for the client; and (2) for purposes of the quarterly assertions and attestations that are required from certified PEOs. * Guidance with respect to what information the Treasury/IRS will require from PEOs regarding the FFCRA and CARES Act provisions utilized by PEO clients. * Gudiance regarding Frequently Asked Questions posted by the IRS on tax credits from the CARES Act, specifically FAQ #93. NAPEO advocated that FAQ #93s discussion of third party liability as inapplicable to PEOs. NAPEO also argued that the reference in FAQ #90 to third party payers obtaining information with respect to the clients claims for credits under section 45S is inapplicable to PEOs when a PEO client is claiming the 45S credit. NAPEO further asked for clarification from the IRS if the position presented to the agency is incorrect.

Lobbying in support of H.R. 1043/S.460, the Employer Participation in Repayment Act, legislation to expand the tax exclusion for employer-provided educational assistance to include payments of qualified education loans by an employer to either an employee or a lender.

Form 5500 Filings: The Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act) contains a provision requiring multiple employer plans, or MEPs, to provide a list of participating employers and a good faith estimate of the percentage of total contributions made by each participating employer during the plan year on the plans annual report (Form 5500) for plan years beginning after December 31, 2013. In response, many PEOs redacted, coded, or filed under separate cover the list of their employer plan participants starting with their 2015 Form 5500 filings, on the grounds that these lists are proprietary and trade secrets. Beginning in February 2019, the Department of Labor sent notices of rejection (NORs) to PEOs that had redacted, coded, or sent under separate cover their employer plan participants on their 2016 Form 5500s. NAPEO continues to ask the Department of Labor and the Employee Benefits Security Administration to use its authority to protect the Form 5500 filings of all MEPs from being disclosed to the public.

Preparation of lobbying material on PEOs and the Occupational Safety and Health Act. Asking the Equal Employment Opportunity Commission (EEOC) to shift the responsibility of filing for EEO-1 from the PEO to the PEO client in those instances where the client has met the threshold/requirements of filing an EEO-1 Form.

Lobbying in support of H.R. 1043/S.460, the Employer Participation in Repayment Act, legislation to expand the tax exclusion for employer-provided educational assistance to include payments of qualified education loans by an employer to either an employee or a lender.

Form 5500 Filings: The Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act) contains a provision requiring multiple employer plans, or MEPs, to provide a list of participating employers and a good faith estimate of the percentage of total contributions made by each participating employer during the plan year on the plans annual report (Form 5500) for plan years beginning after December 31, 2013. In response, many PEOs redacted, coded, or filed under separate cover the list of their employer plan participants starting with their 2015 Form 5500 filings, on the grounds that these lists are proprietary and trade secrets. Beginning in February 2019, the Department of Labor sent notices of rejection (NORs) to PEOs that had redacted, coded, or sent under separate cover their employer plan participants on their 2016 Form 5500s. NAPEO continues to ask the Department of Labor and the Employee Benefits Security Administration to use its authority to protect the Form 5500 filings of all MEPs from being disclosed to the public.

Joint Employer Regulation: NAPEO filed comments with the Department of Labor (DOL) on the proposed Joint Employer notice of proposed rulemaking.

Form 5500 Filings: The Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act) contains a provision requiring multiple employer plans, or MEPs, to provide a list of participating employers and a good faith estimate of the percentage of total contributions made by each participating employer during the plan year on the plans annual report (Form 5500) for plan years beginning after December 31, 2013. In response, many PEOs redacted, coded, or filed under separate cover the list of their employer plan participants starting with their 2015 Form 5500 filings, on the grounds that these lists are proprietary and trade secrets. Beginning in February 2019, the Department of Labor sent notices of rejection (NORs) to PEOs that had redacted, coded, or sent under separate cover their employer plan participants on their 2016 Form 5500s. NAPEO continues to ask the Department of Labor and the Employee Benefits Security Administration to use its authority - in either the ERISA Act or the Freedom of Information Act (FOIA) - to protect the Form 5500 filings of all MEPs from being disclosed to the public.

Form 5500 Filings: The Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act) contains a provision requiring multiple employer plans, or MEPs, to provide a list of participating employers and a good faith estimate of the percentage of total contributions made by each participating employer during the plan year on the plans annual report (Form 5500) for plan years beginning after December 31, 2013. In response, many PEOs redacted, coded, or filed under separate cover the list of their employer plan participants starting with their 2015 Form 5500 filings, on the grounds that these lists are proprietary and trade secrets. Beginning in February 2019, the Department of Labor sent notices of rejection (NORs) to PEOs that had redacted, coded, or sent under separate cover their employer plan participants on their 2016 Form 5500s. NAPEO is asking the Department of Labor to use its authority - in either the ERISA Act or the Freedom of Information Act (FOIA) - to protect the Form 5500 filings of all MEPs from being disclosed to the public.

Implementation of the Small Business Efficiency Act/IRS PEO Certification program - Issues arising from the implementation of a voluntary ceritification program at the IRS for Professional Employer Organizations (PEOs), as well as issues that arise from program requirements, filing requirements, and IRS-mandated reporting requirements. Implementation of tax reform: NAPEO asked the IRS/Treasury to clarify the application of Section 199(A) of the tax reform bill - which provides a 20 percent reduction in taxes for certain pass-through entities - on the clients of PEOs.

Joint employer proposed rulemaking: NAPEO drafted comments on a proposed rule issued by the National Labor Relations Board to clarify joint employment.

S. 2526/HR 858 - legislation to expand the use of Open Multiple Employer retirement plans. NAPEO is working to correct a specific provision within the "one bad apple" provision that might harm retirement plans offered by PEOs. NAPEO is lobbying to fix the potential problem.

Implementation of the Small Business Efficiency Act/IRS PEO Certification program - Issues arising from the implementation of a voluntary ceritification program at the IRS for Professional Employer Organizations (PEOs), as well as issues that arise from program requirements, filing requirements, and IRS-mandated reporting requirements. Implementation of tax reform: NAPEO asked the IRS/Treasury to clarify the application of Section 199(A) of the tax reform bill - which provides a 20 percent reduction in taxes for certain pass-through entities - on the clients of PEOs.

E-Verify

Implementation of the Small Business Efficiency Act/IRS PEO Certification program. Implementation of tax reform: NAPEO has asked the IRS/Treasury to clarify the application of Section 199(A) of the tax reform bill - which provides a 20 percent reduction in taxes for certain pass-through entities - on the clients of PEOs.

S. 2526/HR 858 - legislation to expand the use of Open Multiple Employer retirement plans.

Treatment of EEO-1 Forms filed with the Equal Employment Opportunity Commission by the clients of Professional Employer Organizations.

Implementation of the Small Business Efficiency Act/IRS PEO Certification program. Implementation of tax reform: NAPEO has asked the IRS/Treasury to clarify the application of Section 199(A) of the tax reform bill - which provides a 20 percent reduction in taxes for certain pass-through entities - on the clients of PEOs.

Better Care Reconciliation Act: Draft legislation creates Small Business Health Plans. NAPEO has lobbied Congress to add an amendment to expand participate in Small Business Health Plans to include PEOs.

Implementation of the Small Business Efficiency Act/IRS PEO Certification program.

E-Verify legislation and its application to the PEO industry.

Better Care Reconciliation Act: Draft legislation creates Small Business Health Plans. NAPEO has lobbied Congress to add an amendment to expand participate in Small Business Health Plans to include PEOs.

Implementation of the Small Business Efficiency Act/IRS PEO Certification program.

Procedures for PEOs/PEO clients when inspected by OSHA; legislation to amend the FLSA/NLRA to clarify the definition of joint employment.

Better Care Reconciliation Act: Draft legislation creates Small Business Health Plans. NAPEO has lobbied Congress to add an amendment to expand participate in Small Business Health Plans to include PEOs.

Repeal/overturning new EEO-1 reporting form; Procedures for PEOs/PEO clients when inspected by OSHA; legislation to amend the FLSA/NLRA to clarify joint employment.

Implementation of the Small Business Efficiency Act/IRS PEO Certification program.

Repeal/overturning new EEO-1 reporting form; Repeal of the OSHA Volks Rule (H.Con. Res 83); and repeal of the Blacklisting rule (H.J.Res. 37)

HR 525, the Small Business Health Fairness Act - legislation expanding the use of Association Health Plans to provide insurance for small businesses/potential amendment clarifying the application of legislation to PEO sponsored health insurance plans.

Implementation of the Small Business Efficiency Act/IRS PEO Certification program.

Notice of Proposed Rulemaking to revise Form 5500 and rules governing Form 5500.

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Proposed Changes to the EEO-1 form by the Equal Employment Opportunity Commission

Notice of Proposed Rulemaking to revise Form 5500 and rules governing Form 5500.

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Proposed Changes to the EEO-1 form by the Equal Employment Opportunity Commission

Proposed Changes to the EEO-1 form by the Equal Employment Opportunity Commission

Notice of Proposed Rulemaking to revise Form 5500 and rules governing Form 5500.

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Proposed Changes to the EEO-1 form by the Equal Employment Opportunity Commission

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Proposed Changes to the EEO-1 form by the Equal Employment Opportunity Commission

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Support for a two-year delay of the 40 percent "Cadillac Tax" on employer-sponsored health coverag.

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Request that HUD remove restrictions against FHA/HUD certified lenders from using a professional employer organization.

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

Request that HUD remove restrictions against FHA/HUD certified lenders from using a professional employer organization.

Implementation of the Small Business Efficiency Act by the Department of Treasury and the Internal Revenue Service.

HR 3581/S. 379 the Small Business Efficiency Act (SBEA): Legislation creates a certification program within the IRS for professional employer organizations (PEOs). Certification grants PEOs the ability to collect/remit federal employment taxes; holds IRS-certified PEOs liable for the employment taxes of their clients; and allows certified PEOs to take on new clients mid year without restarting FICA/FUTA withholdings.

HR 3581/S. 379, the Small Business Efficiency Act: Legislation that recognizes the ability of Professional Employer Organizations (PEO) to remit the federal payroll taxes of their small business clients; creates a certification process within the IRS for PEOs; and holds IRS-certified PEOs liable for the payroll tax remittance of their clients.

S. 479/HR 3581, the Small Business Efficiency Act: Legislation that recognizes the ability of Professional Employer Organizations (PEO) to remit the federal payroll taxes of their small business clients; creates a certification process within the IRS for PEOs; and holds PEOs liable for the payroll tax remittance of their clients.

H.R. 1772, E-Verify legislation

HR 3581/S. 479, the Small Business Efficiency Act: Legislation to allow Professional Employer Organizations (PEOs) to remit federal payroll taxes of their clients; creates a certification process in the IRS for PEOs; and holds PEOs liable for the payroll tax submissions of their small business clients.HR 1772, Legal Workforce Act - Amends the Immigration and Nationality Act to direct the Secretary of Homeland Security (DHS) to establish an employment eligibility verification system (EEVS), patterned after the E-Verify system. (Eliminates the current paper-based I-9 system.)

The Small Business Efficiency Act - Legislation that recognizes the ability of Professional Employer Organizations (PEO) to remit the federal payroll taxes of their small business clients; creates a certification process within the IRS for PEOs; and holds PEOs liable for the payroll tax remittance of their clients.

The Small Business Effiency Act: Legislation that recognizes the ability of Professional Employer Organizations (PEOs) to remitt the federal payroll taxes of their clients; creates a certification process within the IRS for PEOs; and holds PEOs liable for the payroll tax remittance of their clients.

The Small Business Efficiency Act: Legislation that recognizes the ability of Professional Employer Organizations (PEOs) to remit the federal payroll taxes of their small business clients; creates a certification process within the IRS for PEOs; and holds PEOs liable for the payroll tax remittance of their clients.

The Small Business Efficiency Act (S. 479) - legislation to affirm the ability of Professional Employer Organizations (PEOs) to remit the payroll taxes of their clients; creates a certification program for PEOs in the IRS.

Patient Protection and Affordable Care Act

HR 2466/S. 1908, the Small Business Efficiency Act: Allows PEOs to remit the payroll taxes of their clients; creates a certification process within the IRS for PEOs; and holds certified PEOs liable for the payroll tax remittance of their clients.

H.R. 2466/S. 1908, the Small Business Efficiency Act - This legislation would create a voluntary certification process within the IRS for Professional Employer Organizations (PEOs); recongnizes the ability of PEOs to withhold and submit payroll taxes for their clients; and ensures that small and mid-sized companies that use PEOs are able to receive tax credits targeted for small businesses.

Proposal clarifying the status of professional employer organizations: HR 2466, S. 1908

Proposal clarifying the status of professional employer organizations; H.R. 2466; S. 1908

Proposal clarifying the status of professional employer organizations; HR 2466; S 1908

Proposal clarifying the status of professional employer organizations; H.R. 2466; S. 1908

Proposal clarifying the status of professional employer organizations; HR 2466; S 1908