October 3, 2013
To whom it may concern:
Please note that as a tax professional I’m familiar with various required reporting regimen. So when I read an article about your proposed rules to implement Section 953(b) I was astonished. If I correctly understand your proposal with respect to how the median wage is calculated and what items are included in “compensation”, there would be no way to create an industry benchmark or some kind of national data base since each company could use a unique formula independent of any other company. So I am wondering…. exactly how is this useful? Common sense would tell you that you would have to use a standardized method in order for the results to have any relevance. It’s as if you are purposefully sabotaging your own tool. Please help me understand your reasoning.
I would be happy to provide some guidance on a cost effective way to calculate median wages and what to include in “compensation”.
Very truly yours,
Paul Glenn
Compton & Wendler, P.C.
909 Fannin, Suite 3275
Houston, TX 77010