Union Pacific Railroad Co. v. United States, No. 16-3574 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit reversed the district court's grant of summary judgment to the government in a suit by Union Pacific to recover a refund of about $75 million in taxes that it paid the federal government from 1991 to 2007 under the Railroad Retirement Tax Act (RRTA). The court held that the RRTA unambiguously does not require payment of RRTA taxes on remuneration in stock. Furthermore, the RRTA does not require Union Pacific to pay taxes when it made so-called ratification payments to employees when their unions ratified collective bargaining agreements.
Court Description: Arnold, Author, with Wollman and Gruender, Circuit Judges] Civil case - Railroad Retirement Tax Act. In a suit to recover a refund of $75 million in taxes the railroad paid the federal government from 1991 to 2007 under the Railroad Retirement Act, the district court erred in rejecting the refund request and granting the government's motion for summary judgment; the Act unambiguously does not require the payment of RRTA taxes on remuneration in stock; additionally, ratification payments made to employees were not subject to the tax because the payments were not made for services rendered to the railroad. Reversed and remanded for further proceedings.
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