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Government Relations
The American Payroll Association is your voice in Washington, DC, and in the state capitals. Our registered lobbyists in Washington, as well as members of the Government Affairs Task Force, represent the concerns of employers, service providers, and software developers before Congress, federal agencies, and state governments.
Our mission is to communicate the concerns of the payroll community to legislative and executive branches of government and to find ways for employers to meet their requirements under law and support government objectives, while minimizing administrative burden and cost for employers, government, and individual taxpayers.
The federal agencies with which APA has excellent relations include:
- Internal Revenue Service
- Social Security Administration
- Office of Child Support Enforcement
- Department of Labor
- Citizenship and Immigration Services
- Immigration and Customs Enforcement
- Federal Reserve Bank
- Federal Deposit Insurance Corporation
- Federal Trade Commission
- Office of Foreign Assets Control
APA's Government Relations staff has received SSA's Public Service Award for its ongoing dedication to improving the quality of employer wage and tax reporting and the IRS's Excellence in Partnering Award for our collaboration on clarifying employers' responsibilities and helping IRS educate employers. At IRS, we are a founding member of the Information Reporting Program Advisory Committee, and we also have representation on the IRS Advisory Council and the Electronic Tax Administration Advisory Committee.
Member input is vital to this process. Through your email, and even more importantly through your volunteer involvement, we're listening to your interests and priorities.
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Current Government Relations Lobbying Efforts
As Pay or Play Provisions Released, APA Provides Comments
The IRS released proposed regulations (REG 138006-12) implementing the employer "play or pay" provisions in the Affordable Care Act. Much of the proposed regulations adopt guidance previously released by the IRS; however, it does contain new information regarding full-time status and educational organizations. After hearing concerns from multiple members, the APA submitted comments to the IRS regarding the proposed regulations.
Read APA's Letter.
APA Urges Expansion of Truncated-TINs
The IRS released proposed regulations which would make the truncated TIN (TTIN) pilot program permanent, thus allowing certain filers of information returns to display the last four digits of the taxpayer identification number on reports. The APA applauded these regulations, but asked that the program be expanded to cover employer identification numbers (EINs).
Read APA's Letter.
APA Continues Efforts Regarding Treatment of Severance Payments
In United States v. Quality Stores, the U.S. Court of Appeals for the Sixth Circuit ruled that severance payments paid to former employees pursuant to an involuntary reduction in force were supplemental unemployment compensation benefits (SUB-Pay) and not taxable wages for FICA tax purposes. The APA has been monitoring this case because of the significant payroll tax implications and filed a memorandum commenting on the court's most recent decision.
Read APA's Memorandum.
With Fiscal Cliff Looming, APA Requests Guidance from Treasury, IRS
The 2013 percentage method withholding tables have not yet been released due partly because of the ongoing fiscal cliff negotiations. The APA wrote to the Treasury and IRS to request guidance on how employers should withhold federal income tax from payments made after December 31.
Read APA's Letter.
As Congress Considers Tax Relief Proposals, APA Offers Assistance
With the two percent social security tax holiday for employees scheduled to expire on December 31, the APA offered to meet with members of Congress to discuss the effects any extension or expiration would have on employers and any other tax relief proposals being considered.
Read APA's Letter.
APA Encourages IRS, Treasury To Update and Expand Hurricane Sandy Tax Relief
The APA submitted comments to the IRS and Treasury requesting reinstatement of special temporary rules allowing employees to donate vacation and sick pay to hurricane Sandy victims.
Read APA's comments. Read APA's Thank You Letter.
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Draft Form I-9 is released, Immigration Subcommittee Weighs In
USCIS released a draft Form I-9 and instructions in March and requested public comment on the proposed form and instructions. The Immigration Subcommittee of the Government Affairs Task Force reviewed the form and instructions and submitted comments.
Read APA's comments.
APA provides updated comments on the Temporary Payroll Tax Cut Continuation Act
The APA submitted updated comments to Congress on P.L 112-78, the Temporary Payroll Tax Cut Continuation Act of 2011. The APA requested member feedback on two questions: - If required, how much time is needed to reprogram payroll systems to allow for 2 different employee social security rates (6.2% and 4.2%) in the same year?
- If the extension is only temporary again, would it be easier to implement the change if it ended at the end of a quarter (March 31, June 30, September 30) or a non-quarter ending month (i.e. April 30, May 31)?
Read APA's comments.
APA presents testimony on IRS's Real Time Tax System
On January 25, Lori Brown, CPP provided testimony on behalf of the APA to IRS officials concerning the IRS's creation and implementation of a Real Time Tax System.
Read APA's comments.
APA provides comments on H.R. 3630
The APA submitted comments to Congress on H.R. 3630, Temporary Payroll Tax Cut Continuation Act of 2011.
Read APA's comments.
APA provides comments on IRS Notice 2011-28
The APA submitted comments to the IRS concerning Notice 2011-28 - Interim Guidance on Informational Reporting to Employees of the Cost of Their Group Health Insurance Coverage. The APA requested feedback from members of our GATF subcommittees to hear any problem areas payroll professionals may encounter when the requirement becomes mandatory beginning with 2012 Forms W-2.
Read APA's comments to the IRS
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APA's Government Relations Staff
Brian O'Laughlin, Esq. Manager of Government Relations
202-232-6888
210-630-4386 (efax)
bolaughlin@americanpayroll.org
Issues: Federal, state, and local taxes; wage reporting to the Social Security Administration; federal tax forms and publications; electronic tax payments; work eligibility and employment verification
William Dunn, CPP Senior Manager of Government Relations
202-232-6889
210-630-4385 (efax)
wdunn@americanpayroll.org
Child support and garnishments, wage payment methods, electronic nontax payments, employment data privacy
American Payroll Association
Suite 1
1601 18th Street, NW
Washington, DC 20009-2505
Fax: 202-232-6882
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| GOVERNMENT AFFAIRS TASK FORCE |
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Members of the Government Affairs Task Force interact with federal and state legislatures and government agencies that regulate payroll matters with the goal of influencing legislation and regulatory activity to benefit APA's membership. GATF subcommittees actively work to achieve this goal as it pertains to their specific subject matter area.
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GATF Auto IRA Subcommittee
The Auto IRA Subcommittee has formed to address federal and state proposals that would require employers to enroll employees in Individual Retirement Accounts. Subcommittee efforts focus on achieving the goals of the proposals while limiting the administrative burden on employers.
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| CHILD SUPPORT & OTHER GARNISHMENTS |
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GATF Child Support and Other Garnishments Subcommittee
The Child Support and Other Garnishments Subcommittee works closely with the Federal Office of Child Support Enforcement to promote the standardization of child support enforcement notices, electronic payment systems, and withholding policies/procedures throughout the U.S.
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| FEDERAL TAX FORMS & PUBLICATIONS |
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GATF Federal Tax Forms and Publications Subcommittee
Forms and publications from the IRS and the SSA constitute important communication between the federal government and employers. Both agencies are always looking for ways to improve the functionality and implementation of their forms. The GATF Federal Tax Forms and Publications Subcommittee researches, reviews, and provides valuable input on these forms for submission to the IRS and SSA.
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GATF Immigration Subcommittee
Employment is the immigration magnet, and payroll professionals play a big role in ensuring that only eligible individuals are working in the U.S. This subcommittee examines the requirements, forms, and programs of two agencies under the U.S. Department of Homeland Security: U.S. Citizenship and Immigration Services (USCIS) and Immigration and Customs Enforcement (ICE).
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GATF Payroll Card Subcommittee
Payroll cards are one of the hottest payroll administration topics and trends for employers and payroll professionals. Learn more about APA's new GATF Payroll Card Subcommittee and the lobbying efforts that this group will embark on to promote new laws and/or regulations that provide employers the option to deploy cost-effective payroll card programs to their workforce throughout the United States.
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GATF SSA Wage Reporting Redesign Subcommittee
The Social Security Administration is planning to redesign its wage reporting process over the next few years. The SSA sees this process as the perfect opportunity to solicit employer input regarding the types of services payroll professionals would like to see implemented and the types of communications we receive. The subcommittee also researches, reviews, and makes recommendations on SSA processes, proposals and regulations that affect the payroll industry.
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GATF Unemployment Insurance Subcommittee
State unemployment trust funds are facing unparalleled challenges to continue to provide benefits to unemployed workers. These challenges impact employers through higher costs, and any changes to address the problem of the trust funds are expected to have further consequences on employers. This subcommittee has been formed to explore the challenges facing the unemployment system in order to provide an employer perspective to federal and state legislators and regulators.
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ARCHIVED LOBBYING EFFORTS
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