The IRS recently issued Notice 2011-72 and a Memorandum for All Field Examination Operations, which provide a road-map for employers to avoid taxing employees on cell phone expenses. Following the de-listing of cell phones as “listed property” under Code section 274(d) last year, there has continued to be some uncertainty on the proper tax treatment of employer-provided cell phones (and reimbursements of cell phone costs) (see

This guidance, summarized below, clarifies the proper tax treatment and is retroactively effective for cell phone use after December 31, 2009.


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