While the One Big Beautiful Bill Act made headlines for tax and spending cuts, it also contains significant changes to the federal government’s treatment of COVID era Employee Retention Tax Credit (ERC) claims — many of which...more
8/5/2025
/ CARES Act ,
Constitutional Challenges ,
Coronavirus/COVID-19 ,
Due Diligence ,
Employee Retention ,
Internal Revenue Code (IRC) ,
IRS ,
New Legislation ,
One Big Beautiful Bill Act ,
Penalties ,
Statute of Limitations ,
Tax Credits
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more