IRS Provides Procedures for ERC Claim Withdrawal: Should Employers Use Them?... [ read ]
We have written numerous times about the employee retention credit (ERC): sometimes about the IRS' focus on unscrupulous refund claims, more recently about how the IRS has stopped processing new ERC claims, and steps employers may want to consider taking. Now the IRS has yet another update regarding ERC issues, most likely motivated by an IRS desire to clear its massive backlog of ERC claims waiting to be administratively processed.
Improper Art Donation Deduction Promotions: IRS Sounds Alarm... [ read ]
The IRS is warning taxpayers not to claim improper art donation deduction and provides tips to help people avoid getting ensnared by an illicit art donation promotion.
Saved by the Bell: Treasury Extends Deadline for Reporting Owners of Newly Formed Entities... [ read ]
Uncle Sam's curiosity is often insatiable. But at least he is willing to wait an additional 90 days, based on a newly proposed rule by the Treasury Department. Of course I'm talking about the new disclosure rules mandated by the 2021 Corporate Transparency Act, which require many private businesses, and virtually all small businesses, to disclose to the U.S. government the identities of their owners and other basic information about them.
Distinctions that Make a Difference: Federal Circuit Holds that Various Substance Over Form Doctrines are Not Interchangeable... [ read ]
There are various interactions of the substance over form doctrine, such as step-transaction, economic substance, sham, among others. As the Federal Circuit reminded us all yesterday, the iterations are not interchangeable. I'm referring to the Federal Circuit's September 21, 2023 decision in GSS Holdings (Liberty) Inc. v. the U.S.
The Squeaky Wheel Gets the Grease? Employers Should Consider Filing Lawsuits to Obtain ERC Refunds... [ read ]
Just last week, the IRS announced that it was no longer processing any new Employee Retention Credit (ERC) claims amid a surge in questionable claims. While there may be questionable claims being filed, there are plenty of legitimate claims that should be processed and refunded to employers.
More Money, More Problems: IRS Further Targets "Wealthy" Taxpayers with New Special Team... [ read ]
After announcing the hiring of new agents to audit the "wealthy," the IRS marches further down the war path by establishing a special pass-through organization to help with high-income compliance efforts.
Adding Bite to its Bark: IRS Announces Hiring of 3,700 to Audit Wealthy Taxpayers... [ read ]
IRS enforcement rhetoric is never a hollow threat. But given the IRS' limited resources historically, the saying "a barking dog seldom bites" sometimes held true. That is no longer the case, with the IRS announcing the opening of more than 3,700 positions to support its latest initiative to expand tax enforcement against high-income earners, partnerships, large corporations and promoters.
IRS Halts Processing of ERC Claims... [ read ]
On September 14, the IRS announced that it was immediately stopping processing of any new Employee Retention Credit (ERC) claims amid a surge in questionable claims. The moratorium on processing is effective immediately and will run through at least the end of the year.
IRS Announces Plans to Focus Examinations on High-Income Taxpayers, Partnerships, Corporations and Abusive Promoters With the Help of AI... [ read ]
On September 8th, the IRS, following a "top-to-bottom" review of enforcement efforts, announced that it will be shifting more enforcement efforts to "high-income earners, partnerships, large corporations and promoters abusing the nations' tax laws".
IRS Targets High-Income Individuals Illegally Claiming Puerto Rico's Tax Benefits... [ read ]
The Internal Revenue Service ("IRS") Commissioner Danny Werfel stated that the Agency is taking "swift and aggressive action" to strengthen enforcement efforts against high-income individuals. As part of these enforcement efforts, the IRS identified approximately 100 individuals, including crypto traders and fund managers suspected of illegally claiming Puerto Rico's tax benefits. According to the IRS, the enforcement efforts will include both civil audits and criminal investigations.
