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15 results

August 20, 2024

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4 min read

Second Employee Retention Credit Voluntary Disclosure Program Provides Relief for Some Employers

On August 15, 2024, the IRS announced a second Employee Retention Credit (ERC) Voluntary Disclosure Program available to certain employers who wish to
self-report that they erroneously received credits for the 2021 tax year. 
...Read more

October 26, 2023

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4 min read

Lights, Camera, Audit: High-Income Taxpayers, Partnerships, Corporations, and Promoters Headline Recently Announced IRS Enforcement Priorities

The Inflation Reduction Act of 2022 (IRA), passed into law on August 16, 2022, represented a shift in the world of U.S. federal tax enforcement. This shift—or
as most might suggest, a reversal of course—departed from the IRS that many have come to know in recent years, maligned by funding cuts, widespread
attrition, and loss of institutional knowledge needed to administer the nation’s complex set of federal tax laws.
...Read more

October 2, 2023

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4 min read

IRS Backtracks on Penalties and Seeks to Settle Case Involving Backdated Documents

September 14, 2023

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6 min read

Tax Court Reproach of “Cut-and-Paste” Notice Another Blow to IRS Documentation Credibility

A Tax Court Memorandum Opinion expressing no confidence that a “slipshod-cut-and-paste” notice of deficiency was the version of the notice actually sent to
the taxpayer is the latest in a string of rebukes from the Court and Congress questioning the IRS’s ability to retain credible and complete records.
...Read more

August 31, 2023

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5 min read

Fallout from Backdated Documents Lands IRS in Hot Seat

Recent revelations involving documents found to be backdated by the IRS in the case of Lakepoint Land II, LLC v. Commissioner resulted in the Tax Court
imposing sanctions on the IRS. Further inquiries ensued as to whether the IRS also proffered backdated penalty documents in other similar cases, hinting at a
troubling picture of potentially systemic issues within the IRS.
...Read more

August 18, 2023

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1 min read

IRS Clarifies Federal Credit Unions May Claim Employee Retention Credit For 2021

In a memorandum released on August 18, 2023 (CCM 202333001), the IRS Office of Chief Counsel clarified the eligibility of federal credit unions to claim
Employee Retention Credits under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) and the Internal Revenue Code.
...Read more

August 7, 2023

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4 min read

Winston & Strawn Tax Impacts Monthly Tax Controversy Update – July 2023

In this installment, we highlight two recent notable court cases, cover recent developments in Washington related to enforcement efforts related to the
Employee Retention Credit (ERC), and highlight recent IRS guidance as to the taxation of staking rewards within the cryptocurrency space.
...Read more

July 31, 2023

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5 min read

IRS Cites Progress as House Committee Hearing Seeks Solutions to Employee Retention Tax Credit Woes

On Thursday, July 20, the House Committee on Ways and Means Chairman Jason Smith (R-MO-08) and Oversight Subcommittee Chairman David Schweikert
(R-AZ-01) announced the Subcommittee’s hearing on “The Employee Retention Tax Credit Experience: Confusion, Delays, and Fraud” to be held the following
Thursday. The announcement served to kick-off an unusually busy seven days of Employee Retention Tax Credit (ERTC) related activity in Washin...Read more
...Read more

April 17, 2023

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7 min read

IRS’s Strategic Operating Plan Includes Objective Targeting High-Income Taxpayers and Large Corporations and Partnerships

The IRS outlined seven initiatives it seeks to accomplish in furtherance of its goal outlined within Objective Three....Read more

August 17, 2022

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2 min read

Biden Signs the Inflation Reduction Act of 2022 into Law

Today, President Biden signed into law the Inflation Reduction Act of 2022 (the “Act”). The Act ushers in, among other things, significant changes to the
Internal Revenue Code and provides additional resources for the IRS.
...Read more

August 8, 2022

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3 min read

Senate Passes Inflation Reduction Act: Latest From the Hill

The Senate has passed the Inflation Reduction Act of 2022 (“Act”), sending the bill to the House, where lawmakers are expected to take up the bill later this
week. The Act’s passage follows a busy weekend on the Hill, which included lawmakers forging ahead with the comprehensive reconciliation bill with formal
debate and the Senate voting Sunday 51 to 50 to pass the reconciliation bill, with Vice President Kamala Harris casting the tie-breaking vote.
...Read more

July 28, 2022

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1 min read

Deal on Senate Reconciliation Bill Announced, Major Tax Provisions Within

Yesterday afternoon, Senator Joe Manchin (D-WV) and Senate Majority Leader Charles E. Schumer (D-NY) announced a last-minute deal—the Inflation
Reduction Act of 2022—containing significant changes to federal tax policy and IRS administration.
...Read more

April 7, 2022

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4 min read

IRS Notices, Additional Actions Expected Following TIGTA Report Assessing Opportunity Zone Compliance

In response to TIGTA’s final report, issued on February 7, 2022, the IRS has agreed to issue notices to potentially noncompliant opportunity zone (OZ) funds
and investors. 
...Read more

December 15, 2021

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1 min read

Insurance Tax Update – IRS Releases Rev. Proc. 2021-54 Providing Unpaid Loss Discount Factors

On December 13, 2021, the IRS released Rev. Proc. 2021-54 containing the discount factors for the 2021 accident year in computing discounted unpaid
losses and discounted estimated salvage recoverable.
...Read more

November 30, 2021

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1 min read

IRS Initiative to Target Large Partnerships Takes Aim October 1

The wait is finally over: The Internal Revenue Service Large Business and International (LB&I) Division will start implementing the Large Partnership
Compliance (LPC) Program within the next two weeks.
...Read more

About This Blog

Winston & Strawn’s Tax Impacts series features timely updates and insights impacting taxpayers, spanning from federal, international, and state and local tax planning to controversy.

Contributors

James N. Mastracchio

Partner

Susan Elizabeth Seabrook

Partner

Related Capabilities

  • Crisis Management
  • Tax
  • Tax Controversy & Criminal Tax

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