For those of us justifiably dissatisfied with this season of House of the Dragon, recent ERC action may lend some much-needed excitement—some might say gore? Last month, the IRS issued nearly 30,000 denial letters to taxpayers for ERC claims it…
With a flurry of IRS announcements regarding wealthy individuals and large partnerships, recent guidance on related-party basis transactions may have been easily overlooked. For many, this oversight may be a non-issue. But some unsuspecting taxpayers may find themselves ill-prepared to…
The IRS has finally come up for air to offer insight into its months-long “review period” of pending Employee Retention Credit (“ERC”) claims. On June 20, 2024, the agency announced that it will begin issuing payments on roughly 10 to…
In an important decision for assessable international penalties, last week the D.C. Circuit reversed a Tax Court decision holding that the IRS could not assess international information return penalties without offering the taxpayer the opportunity to contest them through deficiency…
