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The Employee Retention Credit: A court challenge to IRS guidance

Case: Stenson Tamaddon LLC v. IRS, No. CV-24-01123-PHX-SPL, 2025 WL 1725942 (D. Ariz. June 20, 2025) On June 20, 2025, the US District Court for the District of Arizona denied a motion for summary judgment that was filed...more

“Big, Beautiful Bill”: Federal Tax Bill Would Restrict the Employee Retention Credit

A sweeping federal tax bill that is currently under consideration in the US House of Representatives contains provisions that would significantly change the administration and enforcement of the Employee Retention Credit...more

IRS Roundup April 1 – April 17, 2025

The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax...more

The Employee Retention Credit: IRS’s “Risking” Model Faces Legal Challenge

Case: ERC Today LLC et al. v. John McInelly et al., No. 2:24-cv-03178 (D. Ariz.) In an April 2025 order, the US District Court for the District of Arizona denied a motion for a preliminary injunction filed by two tax...more

FedEx Defeats Government’s Loper Bright Gambit

On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more

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