Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more
Over the past week, the IRS has announced two significant developments in its administration and enforcement of the Employee Retention Credit (ERC). Last week, the IRS' three-part announcement signaled: (i) an end to the...more
As previously indicated, on December 21, 2023, the IRS launched the latest installment in a series of efforts to claw back pandemic-era tax credits erroneously received by ineligible employers. The Employee Retention Credit...more
In an ongoing effort to combat suspect Employee Retention Credit (ERC) claims, on December 6 the IRS announced that it will issue an initial round of more than 20,000 letters disallowing some ERC claims, filed by "fictitious"...more
Much has been written about the Employee Retention Credit (ERC), enacted as part of the CARES Act, and amended and expanded by the Consolidated Appropriations Act (CCA) and most recently, the American Rescue Plan Act of 2021...more
The President's Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, dated August 12, 2020 (Order), directs the Secretary of the Treasury "to defer the withholding, deposit, and payment"...more
The Internal Revenue Service (IRS) has just announced a "sweeping series of steps" to help taxpayers address the challenges of COVID-19 related issues. The IRS "People First Initiative," announced Wednesday March 25, 2020,...more
The President and Congress are taking emergency actions to provide liquidity and other financial relief to taxpayers in response to the coronavirus pandemic. ...more
The 2017 tax reform bill created a new deduction for owners of pass-through entities (partnerships, LLCs taxed as partnerships, S corporations, and sole proprietorships) of up to 20 percent of their "qualified business...more
In three new Q&As issued this past Monday, June 4, 2018, the IRS has provided important guidance and penalty relief for individual taxpayers living abroad or in the U.S. whose "total transition tax liability is less than $1...more
The IRS has just announced that its longstanding Offshore Voluntary Disclosure Program (OVDP) will end as of September 28, 2018. While many U.S. citizens and green card holders living abroad and in the United States have...more
Tax lawyer Stuart Schabes co-presented “FATCA – 2013 and Beyond” at The Perfect Storm: US Tax Legislation and IRS Compliance 2013, a program hosted by Philip Stein & Associates and ERM.
The discussion...more