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Structuring Contracts with Staffing Agencies to Comply with Play or Pay Regulations
Warner Norcross & Judd LLP Link to more items from this source
[Guidance Overview]
Mar. 13, 2014
"In the preamble to the final regulations, the IRS seems to draw a distinction between 'temporary staffing firms' and 'staffing firms'.... where workers are obtained for short periods of time (for example, to meet temporary increases in production, or to cover for employees who are on short-term leaves of absence), the IRS seems comfortable with the idea that the workers are the common law employees of the temporary staffing firm, leaving the temporary staffing firm responsible for offering coverage and liable for paying penalties if coverage is not offered."

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