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Functional US Payroll question (not system-specific) in regards to paying W-2 or 1099

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My client is asking the following question: Based upon my research: when police, who are theoretically “off duty”, provide security services for County buildings, they are still employees and must be paid through payroll (W-2) not as independent contractors (1099). They use County police cars and equipment and wear County uniforms while providing these services. Are there any exceptions related to public safety of which I’m unaware?

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Does anyone have any insight into whether a person must be paid via payroll (W-2)?

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