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Marianna G. Dyson
Of Counsel
Washington +1 202 662 5298 mdyson@cov.com Download V-card

Marianna Dyson practices in the areas of payroll tax, fringe benefits, and information reporting, with a specific focus on perquisites provided to employees and directors, worker classification, tip reporting, cross-border compensation, backup withholding, information reporting, and penalty abatement.

Ms. Dyson advises large employers on the application of employment taxes, the special FICA tax timing rules for nonqualified deferred compensation, the voluntary correction of employment tax errors, and the abatement of late deposit and information reporting penalties for reasonable cause. On behalf of the restaurant industry, her practice provides extensive experience with tip reporting, service charges, tip agreements, and Section 45B tax credits.

  • Assisted a large technology company before IRS Appeals with its successful resolution of an IRS employment tax dispute over the employer's fringe benefit treatment of certain food and beverage benefits.
  • On behalf of a global energy company, successfully resolved a lengthy employment tax dispute with IRS Appeals a covering six calendar years; issues included fringe benefits, cross-border compensation, business expense reimbursements, relocation expenses, settlement payments, information reporting and related penalties, including the abatement of intentional disregard penalties.
  • Launched a successful coalition of large companies from a wide range of industries for the purpose of urging IRS and Treasury to develop simpler rules applicable to substantiating the business use of cellular telephones, BlackBerry smartphones, and similar telecommunications. This initiative was ultimately instrumental in raising awareness of ongoing payroll tax controversies with the IRS, resulting in proposed legislation to remove cell phones from the category of "listed property" under IRS rules.

Pro Bono

  • Internal Revenue Service
    • Special Assistant for Fringe Benefits (Field Coordination), Office of IRS Associate Chief Counsel (Employee Benefits and Exempt Organizations) (1993-1994)
    • Office of IRS Associate Chief Counsel (Employee Benefits and Exempt Organizations), Senior Attorney (1990-1992)

Memberships and Affiliations

  • IRS Commissioner’s Information Reporting Program Advisory Committee, Former Member
  • American Bar Association, Member
  • Chambers USA, Employee Benefits & Executive Compensation (2008-2018)
  • The Best Lawyers in America, Employee Benefits (ERISA) Law and Litigation & Controversy - Tax (2010-2018)
  • Legal 500, Labor & Employment: Employee Benefits and Executive Compensation (2010-2017); Leading Lawyer, (2011-2017); Hall of Fame (2017)
  • Legal 500, Labor & Employment: Employee Health and Retirement Plans (2017)
  • International Tax Review, Women in Tax Leaders (2016-2017)
  • Named to The National Law Journal’s list of Washington’s Most Influential Women Lawyers (2010).