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Articles by Tom Cullinan
States Are Cracking Down On Luxury Car Sales Tax Avoidance
Photograph of a car owned by the brother of former IRS Commissioner Chuck Rettig. Chuck Rettig My law partner Chuck Rettig is a car guy. You know the type. He goes to car shows every weekend, makes sure his own ride is squeaky clean, and can seemingly recite from memory the parts list for vehicles that have not been manufactured in decades.
Is The IRS Done Granting Employee Retention Credit (ERC) Refunds?
Earlier this month the United States Government Accountability Office (GAO) reported that the IRS had “closed all remaining ERC claims, aside from those under examination or appeal, by December 31, 2025.” According to an IRS comment letter attached to the GAO report, the “IRS closed all the remaining non-examined claims by December 31, 2025.
Still Unpaid? Current Thoughts On Recovering Your Employee Retention Credit
Congress enacted the Employee Retention Credit (ERC) to reimburse businesses for retaining employees during the COVID pandemic, allowing employers to retain millions of employees during a time of great uncertainty and serious economic challenges. The hope was that the IRS would quickly and efficiently process ERC refunds that were critical to many employers' ability to weather those challenges.
The Rise of Residency Audits in State Tax Enforcement and Budget Recovery
Residency determinations are relevant for purposes of marital dissolutions, education, probate proceedings, property tax determinations, voter's registration and . . . income taxes. Individuals often erroneously believe they are not residents for tax purposes simply because they spend significant amounts of time or maintain homes outside of a certain state.
Opportunity Knocks: Resolving Tax Issues in the Current IRS Environment
Decades of underfunding and hiring freezes have thoroughly depleted the operations of the Internal Revenue Service, adversely impacting virtually every internal and external function. Recent and forthcoming reductions to the IRS have so severely hampered its ability to enforce tax laws to the point that the IRS and taxpayers must reevaluate long-standing norms about how tax compliance works.
Clean Energy Credits Must Not Become IRS Targets Under Trump Law Original
President Donald Trump’s signature tax-and-spending package, signed July 4, combined with a recent executive order, suggest that the new administration will make green energy tax incentives an enforcement priority. The legislative package eliminates or greatly curtails many of the tax provisions that former President Joe Biden used to incentivize green energy.
What To Do With ERC Refund Claims And IRS Denial Or Recapture Letters
The holidays – and the Internal Revenue Service (IRS) – brought businesses that claimed the Employee Retention Credit (ERC) some very good news. It was not that long ago that the IRS was claiming that the ERC program was rife with fraud. IRS Commissioner Danny Werfel was quoted as recently as March 2024 as estimating that “.” Thankfully, the environment has improved quite a lot over the last several months.
What To Do If The IRS Denies Your ERC Refund Claim
I’ve previously written about Employee Retention Credit (often called the ERC or ERTC) refund claims pending with the IRS here. I’ve also previously shared thoughts for small businesses who, tired of waiting for the IRS to process their ERC refund claims, are considering suing the IRS for their refunds. The IRS recently upped the ante, however, in a press release that said (among other things) that the IRS would soon proactively deny tens of thousands of purportedly “high risk” ERC refund claims.
How To Litigate ERC Refund Claims
Disclosure note: Chuck Rettig, former IRS commissioner and shareholder at Chamberlain Hrdlicka, provided insight and collaborated on this article. In What’s Next For ERC Refund Claims Pending With The IRS?
IRS Likely To Increase Scrutiny On The Puerto Rico Act 22 Tax Break
Puerto Rico's legislature passed Act 22 in 2012, according to critics in Congress, “to attract wealthy foreigners and mainlanders to Puerto Rico by offering generous tax-related benefits.” “For instance,” they add, “after earning Puerto Rican residency status, individuals pay zero taxes for all Puerto Rico-source income, dividends and interests, and capital gains.” According to the IRS, Puerto Rico’s Department of Economic Development and Commerce (DDEC) granted Act 22 benefits to 2,331...
What’s Next For ERC Refund Claims Pending With The IRS?
The latest IRS data shows that it had 1,057,000 unprocessed Forms 941-X as of December 9, 2023. Most of those forms are likely Employee Retention Credit (ERC) refund claims. That number is certainly understated, as IRS Commissioner Danny Werfel told the United States Senate Committee on Finance in mid-April that the IRS was still receiving an average of about 20,000 ERC refund claims per week.
The Internal Revenue Service Is Being Heavy Handed
The IRS typically has three years from the time that a taxpayer files a tax return to assess additional tax. One of the exceptions is if the taxpayer files a fraudulent return, which indefinitely extends the assessment period. Last week, the IRS convinced the United States Tax Court that the fraud exception can apply even when the taxpayer does not act fraudulently.
Multiple ERC Clocks Are Ticking - What To Do Before Time Runs Out
On January 16, House Ways and Means Committee Chair Jason Smith, R-Mo. and Senate Finance Committee Chair Ron Wyden, D-Ore, released the Tax Relief for American Families and Workers Act of 2024 framework. If enacted, the proposed legislation would terminate the Employee Retention Credit (“ERC”) effective January 31, 2024.
Welcome to your new Bee
We have made big changes to The Fresno Bee in print and online, and today you are experiencing those changes in our re-imagined Bee. In print and online, these changes are designed to enhance your reader experience throughout the news day.Today, you are experiencing a state-of-the-art design that gives you greater flexibility in accessing the news you want, and how you want to read it. Our theme, “News All Day.
Coming Tuesday: Your new Bee
For the past several months, we have been working on redesigned print and digital editions of The Bee that meet the needs of readers who consume news much differently than they did a decade ago. On Tuesday, we are transforming The Bee both in print and online to meet the needs of our readers. These changes have come after months of reader interviews and testing of prototypes to determine how best to present our award-winning journalism.
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