Oregon Combined Employer’s Registration

Every company in the State of Oregon with employees must file a Combined Employer’s Registration. The registration is “combined” in the sense that the registration simultaneously takes care of registering the company with both the Oregon Department of Revenue and the Oregon Employment Department. The Oregon Department of Revenue is responsible for collecting state incomes taxes, while the Oregon Employment Department provides many services to Oregon employees, one of the most important of which is providing unemployment insurance benefits to Oregon workers.

Upon successful filing of the Combined Employer’s Registration, an Oregon company will receive from the Oregon Department of Revenue a letter assigning the company a “BIN” Number — this is essentially an Oregon state tax identification number (similar to a federal employment identification number “EIN”). The company owner should also expect to receive separate notices from the Oregon Employment Department informing the company owner whether the company is subject to Oregon Employment Department Law, and, in addition, the notice of the company’s overall tax rate. The BIN number should be used by the company in connection with any filings — including periodic tax filings — with the Oregon Department of Revenue. 

Who Qualifies as an Employee?

It’s important to remember that the Combined Employer’s Registration need be filed only if the company has employees. So, who qualifies as an employee? According to Oregon law, an employee is anyone who performs services for pay for another person or organization under the direction and control of the person or organization.

For purposes of filing the Combined Employer’s Registration, corporate officers, whether of a “C Corporation” or “S Corporation,” will be considered employees, even if that corporate officer is the sole owner of that corporation. In other words, even if an Oregon corporation only has one owner, and no one else participates in the company at all, that single owner will still be considered as an employee of his or her own corporation. Sole proprietors are not considered employees, and neither are single owners of LLCs who have not elected to have the LLC taxed in a manner other than as a disregarded entity. Partners in an LLC taxed as a partnership also are not considered employees of their LLC.

When Must the Filing Be Made?

Before any paychecks are issued to any employees, the Combined Employer’s Registration filing must be made. Most new companies that expect to have employees at the outset make the filing immediately, upon incorporation.