Kostelanetz partner Christopher Ferguson will speak at the IRS Representation Conference on November 8, 2024. He is a panelist for the session “Enforcement Trends: What’s Hot and What’s Not” that will be held from 10:15 AM to 11:05 AM Eastern. The panel will cover a variety of tax enforcement topics,
The Financial Crimes Enforcement Network (FinCEN) announced on Oct. 11, 2024, that it would extend the filing deadline for Reports of Foreign Bank and Financial Account (FBARs Form FinCEN 114) for people impacted by Hurricane Milton as well as those who have been impacted by the war between Israel and Hamas
Bryan C. Skarlatos was quoted in a recent Wall Street Journal article titled “A Tax-Shelter Crackdown Uncovers a Dentist’s ‘Smile High Trust,’” which examines IRS enforcement efforts against tax shelter promotions involving alleged tax-reducing trusts that are targeted to “wealthy individuals, business owners and professionals like doctors and lawyers.” The
The Internal Revenue Service announced this week yet another way for taxpayers to address incorrect Employee Retention Credit (ERC) claims. The agency announced it is opening a “supplemental claim process” to help third-party payers (TPPs) and their clients resolve incorrect claims for the ERCs. This means that TPPs, such as
50,000 low-risk claims could be paid as soon as September The Internal Revenue Service (IRS) touted its rejection of thousands of ERC claims in the agency’s latest update on Employee Retention Credit (ERC) claims today. The announcement contains updated information on claims disallowances but also some good news for businesses
TaxNotes quoted Christopher M. Ferguson on the implications of Loper Bright for IRS enforcement actions against ERC promoters in an article titled “ERC Compliance Announcement on the Horizon,” published July 29, 2024. The article discusses the list of additional warning signs of incorrect claims the IRS recently released to help businesses
By Christopher M. Ferguson Bloomberg Tax August 1, 2024 The US Supreme Court’s ruling overturning Chevron deference, as well as the IRS’s own policies, suggest the IRS may be employing a harsh and legally unsustainable standard in assessing the merits of employee retention credit claims. If true, the IRS may need to
Taxpayers Could Face Penalties, Interest, and Audits If Claims Are Found to Be Erroneous The Internal Revenue Service (IRS) is stepping up its rhetoric regarding potentially fraudulent Employee Retention Credit (ERC) claims, urging businesses to withdraw erroneous claims before the IRS reviews them and issues penalties. Today, the IRS shared
Many nonprofits that were affected by the COVID-19 pandemic have financially benefited from claiming the Employee Retention Credit (ERC). But the ERC has become the source of considerable notoriety over the last several years and is now the focus of significant government enforcement activity. Originally enacted in 2020 as part
On July 2, the IRS published proposed regulations providing that the IRS will assess as an underpayment of tax the interest paid to taxpayers on erroneous refunds of the employee retention credit (“ERC”), as well as other employment tax credits, such as the paid sick leave credit and the paid
