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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

Tax Extenders: What Is Likely To Be Expanded or Modified?

The Coronavirus Aid, Relief, and Economic Security (CARES) Act has provided important benefits for taxpayers in many ways....more

Executive Order "Deferring" Taxes: Notice 2020-65 Postures Guidance

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

Paycheck Protection Program Extended; SBA Releases Borrower Data

On July 4, President Trump signed S. 4116 extending the deadline for applying for a loan under the Paycheck Protection Program (PPP) from June 30 to August 8, 2020. Other than extending the deadline for applying for a PPP...more

Navigating PPP, Employer Tax Deferral, and Tax Credits Under the FFCRA and CARES Act

The President, Congress, the Treasury Department, the SBA and the IRS have been busy enacting and interpreting legislation intended to provide assistance to employers during the coronavirus pandemic, including the...more

Welcome News on PPP Need Certification: Safe Harbor for Loans Below $2 Million, More Clarity for Loans Above $2 Million

Earlier today, the Small Business Administration (SBA) issued FAQ 46 that provides additional guidance related to the certification of need that is required for a Paycheck Protection Program (PPP) loan. As we discussed in a...more

Coronavirus: Significant Tax Provisions in the CARES Act for Businesses and Individuals

President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), providing liquidity and other economic relief to individuals, families, and businesses facing the hardships of the coronavirus...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

Coronavirus: Latest Tax Provisions Implemented in Coronavirus Pandemic Resource Response as of Friday Morning, March 20, 2020

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 Qualified Business Income Deduction: Proposed Regulations Shed Light on Several Key Issues

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

Spotlight on SALT: Wayfair Decision Broadens E-Commerce Sales Tax Responsibilities

Last Thursday, the United States Supreme Court issued its much awaited decision in the case of South Dakota v. Wayfair, Inc., et al. That decision represents a landmark change in the sales tax collection and remitting...more

IRS Finally Provides Important Penalty and Filing Relief on the Section 965 Tax for Qualifying Individuals

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

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

Tax Overhaul Draws New Boundaries Around International Business

The newly passed tax legislation significantly alters the landscape for international business. The final Republican tax cut bill moves the U.S. from a so-called "global taxation regime" to a territorial taxation regime in...more

No Business Left Behind - New Tax Bill Ushers in Significant Changes for All Companies

Long a priority of the Republican Party, the final tax cut bill includes significant simplification and lowering of the taxes paid by corporations. The bill eliminates the corporate Alternative Minimum Tax, creates a new tax...more

President Trump Has Been Inaugurated. What's Next for Tax Reform?

President Donald J. Trump has just been inaugurated as the 45th President of the United States and his proposals regarding tax reform played a key role throughout his entire presidential campaign. Because Republicans retained...more

FBAR Deadlines Not as Close as You Think: New Tax Bill's Language Points to 2017 as Likely Timetable

Thank you for your interest in the 5th Annual IRS Hot Topic Seminar held in Jerusalem in July. In continuing our efforts to provide timely and extremely important updates on tax matters affecting U.S. citizens and green card...more

FATCA – 2013 and Beyond

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

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