When I first started practicing law in the late 1980’s the procedure for making an IRS voluntary disclosure was very simple and informal. The goal of a voluntary disclosure was to correct problems or file delinquent tax...
The Eighth Amendment of the U.S. Constitution provides that excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted. The IRS has for many years calculated penalties...
On August 15, 2024, the IRS announced that they are opening a new ERC Voluntary Disclosure Program (VDP). The new program is similar to the first iteration of the program. Employers will be able to correct improper payments...
On August 15, 2024, the IRS not only announced a second ERC Voluntary Disclosure Program (VDP), they also announced that this fall they would be mailing a large volume of letters (“up to 30,000”) reversing...
Having been involved in ERC matters for some time now, we have been waiting for the IRS to finally act—and act in a material manner—with respect to its massive inventory of pending ERC claims. The IRS is finally acting....
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