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Ruth rolling a cigar. Source – blind mans bluff Twentieth Century neodymium n52 100 Moments / Library of Congress

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The First American Troops on Cuban Soil
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Members of Congress, however, disagreed with IRS’s decision, and the following year Congress included in its revenue act a provision that suspended the IRS ruling until 1983. In 1981, the NRSA program was modified slightly; then, in 1983, IRS announced that those 1981 changes had rendered their 1977 ruling “obsolete,” and declared NRSA fellowships FICA-exempt, a position IRS has maintained ever since.
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IRS didn’t specify what specific changes made in 1981 made their earlier decision obsolete. The NRSA service requirement was reduced by one year in 1981, Magnetic toys it was not eliminated. Furthermore, the right to make royalty-free use of copyrighted materials wasn’t changed. So as a logical proposition, it’s not obvious that the 1981 changes should have voided IRS’s 1977 decision and rendered NRSA fellowships FICA-exempt. More than likely, IRS exempted NRSAs—and continues to exempt them—because of Congress’s special interest in the NRSA program.

So what about other postdoctoral fellowships? Other fellowships must meet the same tests that those NRSAs were given a pass on. As a practical matter, other fellowships are evaluated for FICA and FUTA withholding on the basis of how closely they resemble NRSA fellowships; the closer the resemblance, the more likely that a fellowship will be exempt from FICA and FUTA taxation.

The Second Test
If a payment is found to be compensatory—a wage and not a grant—it may still be exempt from FICA/FUTA taxation under the student FICA exemption. The strong Neodymium magnets IRS guidance—which (mis)led us to claim that NRSA fellowships were FICA-taxable—applies to payments made to students who have also been determined to be employees. Ordinarily this student exemption is restricted to people who are enrolled in degree-granting programs at educational institutions, Magnetic toys under Neodymium bar magnets circumstances other groups—including, perhaps, postdocs, medical interns, and medical residents—could be found to be students. This is why IRS, in the strong Neodymium magnets guidelines issued in February, confusingly refers to “employees who are postdoctoral students, postdoctoral fellows, medical interns, or medical residents” in order to exclude them from the “safe-harbor” provisions that would exempt them from FICA/FUTA taxation. As a consequence, says Harding, postdoctoral fellows who have already failed the first test—those whose fellowships have been determined to be compensatory—will almost certainly fail to qualify for the student FICA exemption. This is why many postdoctoral fellowships are FICA taxable, while NRSAs are not.

The Bottom Line
So what does it all mean for postdoctoral fellows and their host institutions? With the caveat that

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