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Accountable Plan Reimbursements May Not Substitute for Wages
Deloitte via BenefitsLink 
[Guidance Overview] July 12, 2011
[A]n employer may not structure its compensation arrangement so as to avoid the payment of employment taxes by substituting reimbursements and expense allowances for amounts that would otherwise be paid as wages, as illustrated by a temporary reduction in an hourly wage amount only for as long as the tool rate amount is paid.
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