26 U.S.C. § 3306(c)(7) excepts from the definition of "employment"—and thus exempts from the payment of employment tax—"services performed in the employ of an Indian tribe, or any instrumentality" of a tribe. Thus, the Ninth Circuit holds in Blue Lake Rancheria v. United States, a 53-member tribe can create a corporation that "hires" existing workers at other companies, rent those employees back to their original employers, and split the tax savings. Everyone wins! Except taxpayers. [Martin via Wallace]