Tax Blog

Members of our Tax Controversy & Litigation practice filed comments last week on the proposed regulations published July 2, 2024, regarding the Employee Retention Credits. They argued that these proposed regulations exceed the IRS and Treasury authority. They also urged these bodies to abandon the current proposed regulations as they relate to the ERC, and to reconsider the appropriateness of the final regulations treating excessive ERC refunds as underpayments of tax, particularly in light of the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo. 

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