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IRS Issues New Guidance on ERC Program – Should You Hold or Fold?

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

IRS Launches Employee Retention Credit Voluntary Disclosure Program – Is It Time to Hold or Fold?

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

IRS Increases ERC Enforcement and Prepares to Launch New Voluntary Disclosure Program

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

Creative Approaches to the Employee Retention Credit

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 IRS Wants to Help

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 Perils Facing a U.S. Person Having an Undeclared Offshore Financial Account

There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...more

No News is Not Always Good News: IRS's Offshore Voluntary Disclosure Program is Ending

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

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