Assume that meals are served at a trustees meeting. For the purposes of the de minimis reporting exemption on Form LM-10, should the breakfast, lunch, snack, and dinner expenses be combined?
A51. Yes. All expenses in a single fiscal year to a single union official should be combined to determine whether the de minimis exemption is available. See FAQ, Question 50. Meals provided to different union officials are not aggregated when applying the de minimis exemption. See FAQ, Question 2, for examples of persons acting for an employer. Q52. Does the answer change if different caterers provide each meal? Does the answer change if one caterer provides all meals? What if the caterer bills one amount for all of the meals without itemizing the cost for each meal? A52. No. The number of caterers or their billing practices is not relevant. The employer should instead focus on the total value of the meals it provided the union official. If the invoice is not itemized, reasonable good faith estimates may be used to determine the overall value of the meals that each officer received. Q53. Is a company required to file a Form LM-10 if it provides refreshments at a series of labor-managem
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