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....
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. Yesterday, the...
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. We wrote about the IRS moratorium here. While there may be...
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...
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...
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