IRS Chief Counsel: Information returns not required of motor carrier

Information returns not required of motor carrier

The Office of the IRS Chief Counsel publicly released a field advice memorandum* concluding that a motor freight carrier is not required to file information returns, pursuant to section 6041, to the extent that the subject payments are for freight hauling services. 20151002F (release date March 6, 2015, and dated June 6, 2014)

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The IRS Chief Counsel memo [PDF 102 KB] concludes that:

  • Payments of bills for freight are exempt from the information return requirement of section 6041, but the information provided did not conclusively establish that all of the company’s payments were for freight hauling services
  • The definition of “broker” does not include an entity like the freight carrier, that contracts separately with shippers and haulers of freight


*Field advice memo documents are prepared by IRS field attorneys in the Office of Chief Counsel, are reviewed by an Associate Office, and are subsequently issued to IRS field or service center employees. The memo cannot be used or cited as precedent.

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