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IRS Announces a Second Voluntary Disclosure Program for COVID-Era Employee Retention Credit Claims

On Aug. 15, 2024, the IRS announced the much-anticipated reopening of a second Voluntary Disclosure Program (the “Second ERC-VDP”) to help businesses address incorrect Employee Retention Credit (“ERC”) claims as the agency...more

IRS Prepares for Next Stage of Combating Fraudulent Pandemic-Related Employee Retention Credits (ERCs)

On June 20, following a long and detailed review process, the IRS announced its plan to deny tens of thousands of highest-risk Employee Retention Credit (ERC) claims while resuming the processing of only the lowest-risk ERC...more

Voluntary Disclosure Program Announced for Pandemic-Related Employee Retention Credits

On Dec. 21, 2023, the IRS announced the Employee Retention Credit Voluntary Disclosure Program (ERC-VDP), which helps eligible taxpayers pay back the money they had received for erroneously filed Employee Retention Credit...more

Pandemic-Related Employee Retention Credits: Increasing IRS Scrutiny and Related M&A Considerations

The IRS continues to focus on combating perceived fraudulent claims relating to the COVID-19 pandemic-era Employee Retention Credits (ERCs). On Oct. 19, the IRS announced a special process allowing taxpayers to withdraw...more

Final Treasury Regulations Clarify Business Interest Deduction Limitation

Background - On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the deductibility of business interest expense (BIE) under Section...more

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

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