Where multiple employers pay a portion of a single reportable payment, who files the Form LM-10?
A57. Each employer must file a separate Form LM-10 for the amount it paid. For example, where an employer that provides services to a pension and welfare plan takes a union official who is also a trustee of the plan to dinner, and divides the cost among two other investment management firms, each firm must file a Form LM-10 because each is an employer that has provided a thing of value to a union official, unless an exemption, such as the $250 de minimis exemption, is applicable. In determining the applicability of the de minimis exemption for payments to union officials, described in the response to question 15, the employer should consider only the amount it individually contributed. Form LM-10 Instructions, Part A, Item 8.a.
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- Where multiple employers pay a portion of a single reportable payment, who files the Form LM-10?