It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more
4/23/2025
/ Business Taxes ,
Corporate Counsel ,
Employee Retention ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Statute of Limitations ,
Tax Credits ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Refunds ,
Tax Returns
On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more
4/9/2025
/ Corporate Counsel ,
Employee Retention ,
Employees ,
Employer Liability Issues ,
Filing Requirements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Popular ,
Reporting Requirements ,
Tax Credits ,
Tax Liability ,
Tax Planning ,
Tax Returns
The Internal Revenue Service (IRS) recently released IRS Form 15620, Section 83(b) Election (Form 15620), an approved form for taxpayers to use to make a Section 83(b) election. A taxpayer is not required to use Form 15620 to...more
The Treasury Department and IRS on Wednesday issued an eagerly awaited notice of proposed rulemaking to incentivize clean energy facilities: the “clean electricity production credit”—Section 45Y credit—and “clean electricity...more
6/4/2024
/ Clean Energy ,
Energy Storage ,
Greenhouse Gas Emissions ,
Inflation Reduction Act (IRA) ,
Interconnections ,
Internal Revenue Code (IRC) ,
IRS ,
Notice of Proposed Rulemaking (NOPR) ,
Production Tax Credit ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more
4/24/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Digital Wallets ,
Internal Revenue Code (IRC) ,
IRS ,
Know Your Customers ,
Reporting Requirements
In this episode, we are joined by Special Agent Jonathan Schnatz, Senior Analyst with IRS Criminal Investigation. Special Agent Schnatz will discuss his work with an international law enforcement and tax compliance group, and...more
3/5/2024
/ Criminal Investigations ,
Criminal Liability ,
Criminal Prosecution ,
Income Taxes ,
IRS ,
Tax Evasion ,
Tax Fraud ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
White Collar Crimes
On January 31, 2024, the United States House of Representatives passed the Tax Relief for American Families and Workers Act of 2024 (TRAFW Act), which is now under consideration in the Senate. The TRAFW Act, in addition to...more
The current draft of the Tax Relief for American Families and Workers Act of 2024 includes a proposed provision that would dramatically accelerate the deadline to file claims for the Employee Retention Credit (ERC) to January...more
Summary -
The IRS recently released guidance with respect to the new tax credit direct payment and transferability rules created under the Inflation Reduction Act enacted last August. The guidance explains how to register...more
7/3/2023
/ Clean Energy ,
Energy Projects ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Investment Tax Credits ,
IRS ,
New Guidance ,
New Rules ,
Production Tax Credit ,
Proposed Guidance ,
Real Estate Development
Summary -
The IRS recently advised that many organizations that develop paid name, image, and likeness—known as NIL—opportunities for college student-athletes are not eligible for tax-exempt status under Internal Revenue...more
Summary -
In November 2022, the IRS updated its guidance regarding who can sign Form 2848, Power of Attorney and Declaration of Representative (POA), submitted on behalf of a limited liability company (LLC) treated as a...more
Background -
The Internal Revenue Service (IRS) introduced Schedules K-2 and K-3 beginning with tax year 2021. Schedule K-2 (Partners’ Distributive Share Items−International) and Schedule K-3 (Partner’s Share of Income,...more
Due Date for 2020 Tax Returns and Most Payments Extended to May 17, 2021; Estimated Taxes Still Due April 15, 2021 -
Due to lingering concerns related to the pandemic and material changes to the tax laws in the American...more
Included as part of the Stimulus Bill (the Bill) are the COVID-Related Tax Relief Act of 2020 and the Taxpayer Certainty and Disaster Tax Relief Act of 2020. For a discussion of other aspects of the Bill, see our...more
In Revenue Ruling 2020-27, the IRS announced that taxpayers cannot deduct expenses paid for with the proceeds of a Paycheck Protection Program (PPP) loan that is forgiven, even if the PPP loan forgiveness occurs in a later...more
In light of the ongoing pandemic, the Pennsylvania Department of Revenue announced that the due dates for many Pennsylvania individual and business tax returns have been extended....more
Late in the afternoon on Friday, August 28, Treasury issued Notice 2020-65 providing guidance implementing President Trump’s Executive Memorandum on social security payroll tax deferral (Payroll Tax Deferral). President...more
8/31/2020
/ Executive Orders ,
FICA ,
IRS ,
Lost Wages ,
Minimum Wage ,
Payroll Taxes ,
Presidential Memorandum ,
Social Security Taxes ,
Tax Deferral ,
Trump Administration ,
U.S. Treasury ,
Wage and Hour
Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more
8/19/2020
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Popular ,
Private Equity ,
Proposed Regulation ,
Real Estate Investments ,
Tax Cuts and Jobs Act
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
8/14/2020
/ Business Taxes ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Reform
The IRS released a final version of Form 941 (the employment tax return to be used by employers for the second quarter for 2020) and a revised set of accompanying Instructions. The Form and particularly the Instructions...more
6/30/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Form 941 ,
IRS ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Relief Measures ,
SBA ,
Small Business Loans ,
Tax Deferral ,
Tax Planning
The Internal Revenue Service (IRS) issued Notice 2020-46 providing guidance to employers whose employees forgo sick, vacation, or personal leave to aid victims of COVID-19....more
As we noted in our alerts on March 19 and March 20, Treasury extended certain income tax filing and payment dates to July 15, 2020. On April 9, in Notice 2020-23, many more deadlines have been extended. Payment obligations...more
The IRS issued Rev. Proc. 2020-23 allowing partnerships subject to the BBA partnership audit rules to file amended returns to take advantage of retroactive tax benefits in the CARES Act, including the qualified improvement...more
The IRS released FAQs addressing the Treasury’s decision to move Tax Day (for both filing and payment) from April 15 to July 15, 2020....more
The D.C. Office of Tax and Revenue announced on March 23, 2020 that, in step with the federal deadline extensions announced by the IRS on March 20, 2020, the deadline for taxpayers to file and pay their 2019 individual,...more