Existing case law gives the I.R.S. ample authority to challenge at least some amount of the "true up" payments as remuneration for services rendered.
The amendments made by this section [amending this section and sections 861 and 863 of this title] shall apply to remuneration for services performed in taxable years beginning after December 31 , 1997
In Spicer Accounting Inc. vs. United States, for example, the United States Court of Appeals for the Ninth Circuit held that "regardless of how an employer chooses to characterize payments made to its employees, the true analysis is whether the payments are for remuneration for services rendered".
The Ninth Circuit, in analyzing the nature of the payments made to Spicer, maintained that "salary arrangements between closely held corporations and its shareholders warrant close scrutiny". In an effort to determine if the distributions truly represented remuneration for services, the Ninth Circuit established a line of analysis that would be followed repeatedly in the years to follow.
However, remuneration for services to the king, officials and temples were often made in the form of land revenue.
Several factors have been proposed to explain the declining interest in primary care, such as lower remuneration for services provided by primary care physicians compared to sub-specialists, increased educational debt for medical students, and the demands of primary care practice [ 6].
Decision-makers must also review professionals' working conditions and their remuneration (fee-for-service or not) as well as incentives and regulations adopted to attract and retain health professionals in the health sector.
Stop paying dividends and instead pay out the profits as remuneration for "director services" and/or "CEO services" to themselves and/or Jeannie S., as applicable.
Jāgīrs remained a crucial form of remuneration for military service, and, in the directly taxed lands, officials bearing the title of kārdār (agent) were appointed at the level of a unit called as elsewhere in Mughal domains the taʿalluqa (district).
First, there is the immediate incentive of financial remuneration for the service provider, e.g., a usage fee.
The former required a certificate of convenience and necessity to manufacture ice, and the latter prohibited employment agencies from receiving remuneration for their services.
