Thomas M. Cryan

Select representations include:

• A large biotechnology company in the application of the IRS rules impacting spousal travel, the personal use of corporate aircraft, mixed business/personal flights, and the deduction disallowance rules for the entertainment use of corporate aircraft.
• An employer with a highly mobile workforce in designing internal procedures for the proper taxation of travel reimbursements and per diem payments.
• A Fortune 100 company at IRS appeals on the tax treatment of relocation reimbursements and the use of corporate aircraft. IRS conceded the issues in full.
• A Fortune 100 company in a meeting with the Department of the Treasury regarding the taxation of wellness programs.
• An employer on the taxation of an on-site employer cafeteria and the tax treatment of conferences and conventions.
• A large financial institution with internal restructuring in order to avoid FICA restart provisions, and therefore reduce the company's out-of-pocket employment tax costs, while addressing the company's concerns regarding its internal payroll tax administration.
• A large manufacturing company in protesting a large employment tax deposit penalty. Penalty was abated at IRS appeals.
• A large multi-state employer to defend a state income tax audit regarding the withholding of non-resident wage income.
• Various clients in obtaining more than a dozen Section 162(m) private letter rulings (PLRs).
• An acquisition target company to analyze potential Section 280G implications of compensation plans and employment agreements.