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How a Tax Law Helps Insure a Scarcity of Programmers (1998)

223 pointsby Jasberover 15 years ago

20 comments

grellasover 15 years ago
I have dealt with this law in depth, from every angle, from its inception in 1986 and have a few observations to make about it:<p>1. The technical issue concerns the tax risk to an employer whether someone functioning as an independent contractor might be reclassified as an employee via an IRS audit that finds that the person is in fact functioning as an employee and not as someone who runs his own business. This risk exists for every business, large or small, that hires contractors. And the rules by which the outcome is determined are positively byzantine and pretty hostile to employers (and to contractors). They are set forth in IRS Revenue Ruling 87-41 and are summarized here (<a href="http://www.morebusiness.com/running_your_business/taxtalk/indvsemp.brc" rel="nofollow">http://www.morebusiness.com/running_your_business/taxtalk/in...</a>). In general, they state that if an employer has the right to control the means and manner by which someone performs his duties, as opposed to being concerned strictly with the result, then the person is functioning as an employee. They also set forth a list of 20 factors that auditors are to use to help to decide the issue, making this legal determination a very detailed facts-and-circumstances determination that can easily turn one way or the other depending on how an auditor chooses to apply a range of detailed factors. In the background, the law also has cases, precedents, administrative decisions and rulings, etc. that boggle the mind in their complexity concerning how the "rules" work. Moreover, the penalties associated with having a group of contractors reclassified as employees can be extreme. The employer must not only pay employment taxes (Social Security, etc.) for all such persons but also associated penalties and interest. The kicker in the case of a major audit covering several years is even worse because, if the employer can no longer locate the persons involved to get them to sign affidavits attesting that they in fact paid income tax on the income received, the employer also gets stuck having to pay the estimated <i>income</i> taxes for each such reclassified person. In practice, this can amount to a penalty that amounts to nearly half of the wage base involved in the dispute.<p>2. As one might imagine, this is a horrible landscape for companies to try to traverse without something that eliminates or sharply limits the above risks when they deal with contractors. And, to what should be nobody's surprise, such limits have historically existed to enable companies to have some rational means of dealing with the contractor issue. The limits appear in what are called "safe harbor" classifications. This means that a company hiring contractors can <i>know with reasonable certainty</i> that there will be no reclassification of the contractors as employees as long as the company complies with the safe harbor rules. These rules in turn vary from industry to industry but every industry has them. This is how companies hire sales people as contractors, for example, without incurring major risks of tax liabilities.<p>3. The 1986 law referred to in this article repealed the "safe harbor" provisions for providers of high-tech services. Thus, there was no law passed that said, "You are barred from hiring tech service providers as contractors." Companies can hire such contractors as much as they like. The repeal of the safe harbor for this type of service provider (and for <i>no other</i>) had the practical effect of making such service providers unmarketable to companies that had no interest whatever in taking on major tax risks just to be dealing with contractors as opposed to employees.<p>4. Just a background note on this repeal. Before the 1986 repeal, it was true that companies throughout Silicon Valley would hire "contractors" who would literally do, e.g., a 3-year stint working full-time at one desk for one supervisor on one project. Whatever else these persons were, they were clearly functioning as employees. They had to report for work at designated times and in a designated place. They took direct orders from supervisors on when, how, and where to perform specific duties throughout the course of a project or series of projects. There was nothing in such relationships remotely resembling a situation of a company dealing with a person who was in his "own business." In essence, what the companies were doing was hiring employees, calling them contractors, and saving the trouble of having to pay them employee benefits and employment taxes for their services. These were clearly abuses, and they prevailed at all sorts of Valley companies (Intel, HP, all the biggies). Thus, by 1986, this was an area ripe for attack. How did this happen in Congress? Well, 1986 was the great bipartisan coming-together for the lowering of individual tax rates in exchange for closing a variety of tax loopholes and tightening of tax requirements. In the midst of this bipartisan compromise, Congress took note of the abuses happening in Silicon Valley and repealed the safe-harbor classifications for high-tech service providers as a means of eliminating what was perceived as an abusive loophole.<p>5. While the above explains why the tech industry happened to get singled out as it did in 1986, it does <i>not</i> eliminate the fact that this safe-harbor repeal was in fact a highly discriminatory act in that every industry in American had safe-harbor rules available to it so that it could reasonably hire contractors while the tech industry was suddenly left without any such rules at all. Thus, from 1986 forward, tech companies became terrorized at the thought of hiring contractors under any circumstances (by the way, one of the last holdouts, Microsoft, continued to use large numbers of contractors and got slammed for this in major rulings that came out by the early 1990s, if I recall, though that case involved much more than tax issues).<p>6. Almost instantly from 1986 and on, a cottage industry sprang up of "placement agents" who would, in effect, assume the employee risk by hiring the tech-service providers directly and, in turn, contracting with companies to place them there as contractors. This worked for the tech companies because, from their perspective, they simply signed a contractor agreement with the placement firm and paid for the work as contract work. The placement firm, for its part, would then hire the tech-service providers mostly as W-2 employees and occasionally (if they were adventuresome) as contractors. If they retained individuals as contractors, though, they ran the risk of having those persons reclassified as employees and so faced the risk at their level that the tech companies once had directly. Because of this risk, most placement firms would not take on tech people as contractors unless they could have what they perceived as a strong case of calling them true contractors. The practical result of this was that, if a tech-service provider wanted to hire on to a placement firm as a contractor, he would first have to incorporate himself and then the placement firm would take on his company. The irony here is that the tax regulations behind the 1986 repeal specifically provided that it was irrelevant whether or not a sole contractor had incorporated himself and that this fact was to be disregarded in making the tax determination. Thus, though the fact of incorporation was technically irrelevant, most placement firms were happy to take people on as contractors once they had become incorporated. Go figure. (This article, by the way, discusses how the IRS would target such incorporated individuals in search of audit opportunities).<p>7. After 1986, it became virtually impossible for a tech service provider to hire himself out directly to a company as a contractor. Every one of the large Valley companies adopted strict rules forbidding this. In rare cases, someone might get through the rules if the person was incorporated but even then most times the answer from the company was no. Companies simply re-did their hiring practices and thereafter took on contractors pretty much strictly through placement firms and no longer directly.<p>8. For a tech service provider looking to go into business, this essentially put up an impregnable practical wall to finding reasonable opportunities to work independently in the tech world, at least in terms of providing services to the larger companies. This remains the case today as well, since the law has not changed in the decade following publication of this article.<p>9. By the way, this is not just a "big company" issue. Even little businesses can get into trouble without the benefit of safe-harbor protections. If you as a founder hire an early-stage contractor (which is often done) and later terminate the relationship, that person can go file for unemployment on the theory that he was in fact an employee of your company and had functioned as such. This in turn can easily trigger an audit of your entire company's history in this area (1099s you have issued are an easy way for the auditors to focus on key areas). Should this happen to you, you find yourself going down a rabbit hole that is likely to be unpleasant. (An aside: one reason to incorporate as a startup is that reclassification penalties/taxes apply only to the entity and not to the founders directly).<p>10. To sum up, then: there is no law forbidding tech people from offering their services as independent contractors but such persons face serious practical barriers in building a service business because employers will not hire them as contractors for fear of having their status reclassified in a later audit. This is pure discrimination against tech people. No one else is burdened in this particular way in wanting to set up a service business. The fix is an easy one for Congress to make but I have seen no movement on this whatever. For the near future, I am afraid tech service providers are stuck and have no real remedy for this problem.
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jboothover 15 years ago
For those who didn't read all the way down, this law was passed in order to pass a tax cut on overseas operations that IBM was lobbying for. PAYGO rules and all that.<p>Your congress at work -- raise taxes on the little guy in order to give tax breaks to the wealthiest.
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tedunangstover 15 years ago
Have things changed? I had no trouble working as a 1099 for a while, nor did any friends. HN and reddit are filled with posts by people claiming to be independent contractors.<p>How is that one guy with plane is affected by this law, but nobody I've ever talked to is?
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ww520over 15 years ago
Here's my experience working as an independent status. Once a megacorp wanted to hire me as a consultant. The problem was that this megacorp had a list of "approved-vendors" to do consulting work for them. To get into the list was a time consuming and expensive hurdle. What did the hiring manager do? He asked me to join one of these approved vendors temporarily and billed through them. And this vendor got a cut out of it. Apparently it's a common problem that they did it alot. When I told the consulting firm my agreed rate was $200/hr, the guy said their contracting rates were never even close to that. Sweet time.
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andrewljohnsonover 15 years ago
Insure -&#62; Ensure<p>As an ex-college-newspaper editor, this error always stands out to me. And the NYT should know better.... even in 1998. YC's headine is the same as the Times.
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Psyonicover 15 years ago
Thanks for posting this. It provided the best explanation so far (for me, at least) of the law that so pissed off Joe Stack.
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retroover 15 years ago
Does this mean if you're a freelance programmer, you're at risk of running afoul of this law - as Joe Stack did - if you're trying to negotiate programming contracts directly with the client rather than through an agency?<p>My understanding is that you can protect yourself from this law by working through employment agencies as a W2 or Corp-Corp contractor?<p>Is that correct?<p>Is so, then perhaps the programmers I've met who said they were "independent consultants" were likely working through agencies since the risks of being truly independent are too high?
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fnid2over 15 years ago
<i>''This is Catch-22,'' he said. ''If you are not legitimate because you start out as a one-person corporation and you haven't been in business for a year, then how do you ever start your business? It is nonsensical.''</i><p>Save up at least a year's living expenses, get rid of everything you own, travel the world for a year. You'll save money over keeping it, see the world, write some code on your laptop at hotels. Get one of those netbooks that will fit in a backpack. Charge it up at the coffee shop. You can get good wireless cheap overseas. Room and board is cheap.<p>Make arrangements to work with companies while you are away. Start getting paid the next tax year.<p><i>''Basically the I.R.S. is saying it would rather collect less revenue with less cheating than collect more revenue with more cheating. Does that make economic sense?''</i><p>It is interesting that what is proposed here as more profitable government policy encourages cheating, something we don't appreciate in our species.
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CoryMathewsover 15 years ago
Wow.. just wow. what a load of crap, I cannot even imagine how many people are working "illegally". Most every programmer I know does some work on the side as a 1 person operation.
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scotty79over 15 years ago
In my country there is a problem with employers forcing their employees to fictionally incorporate, so employer can save on social security (in case of 1 person companies social security is not associated with actual income, but can be paid in low minimal monthly amount, of course lower monthly social security payments means lower retirement benefits which is not good for fictionally incorporated employees).<p>Our IRS equivalent decides that incorporation was fictional if former employee has 1 person company, has only one client and this client is his former employer. If you have multiple clients and none of them hired you before you started your own company then you are safe.
fexlover 15 years ago
The movie "Brazil" premiered in 1985, the year before strutting beasts wrote this statute in defiance of common law. Many wilt helplessly at the sound of such braying -- but not Tuttle, who embraces the dangerous life of peaceful production.
ajrossover 15 years ago
This is confusing. The clear text of the article says that programmers can't do individual contracting, which is insane and clearly wrong. The examples (e.g the contracting company with 50 "workers", none of whom were technically "employees" of anyone but themselves) don't seem nearly so clear cut.<p>I mean, if this is really an important law to understand, wouldn't the idea of good journalism be to tell me how to avoid breaking it? I don't see that at all here. It reads like just another "tax is bad" screed.<p>A pointer to the text of the law, or a less sensationalist presentation would be very appreciated.
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artanis0over 15 years ago
Anyone know if any laws like this exist for Canada?
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huhertoover 15 years ago
Isn't the root cause of all of this, the high cost of employing people(as opposed to just contracting them). I don't know if it is the situation elsewhere but here in Mexico; the benefits than a low income employee gets are worth the extra employments cost; but for higher income, you just get too many taxes and little benefits, so it is costly for companies without the employees getting much. So people hire contractors to avoid paying so much in benefits that are not worth much.
prgmaticover 15 years ago
This is rediculous, I'm just glad to see that this has resurfaced and people are taking notice.
petercooperover 15 years ago
There's a similar law in the UK. It was passed in the early 2000s, I believe - it's called IR35: <a href="http://www.contractoruk.com/ir35/what_is.html" rel="nofollow">http://www.contractoruk.com/ir35/what_is.html</a>
sownover 15 years ago
Wait.<p>Does this mean that my dream of starting a side business of writing kernel code for hire in SV is DoA?
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kevinpetover 15 years ago
Is this the reason Joseph Stack flew his plane in the IRS building?
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CoryMathewsover 15 years ago
anyone got a link to the actual law itself?
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dnsworksover 15 years ago
Reading through that article a couple of times was like a high school student attempting to write in the spirit of Kafka. It almost feels like an urban legend amongst geeks.