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  • Posts by John W. Hackney
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    John Hackney specializes in Federal and state tax controversy matters and tax litigation, including tax-related examinations and administrative appeals involving individuals, business enterprises, partnerships, limited ...

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Members of Tax Controversy & Litigation Practice File Comments on Proposed Employee Retention Credits Regulations
Posted August 19, 2024 by Larry A. Campagna, Tom Cullinan, John W. Hackney, Philip Karter, Samuel T. Kuzniewski, Kristen S. Lowther, Charles Rettig, Kevin F. Sweeney, Leo Unzeitig, Jaime Vasquez, Victor J. Viser

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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IRS to Begin Paying Certain ERC Claims and Denying Others
Posted June 21, 2024 by Tom Cullinan, John W. Hackney, Charles Rettig

IRS ERC ANNOUNCEMENT (IR-2024-169, June 20, 2024) - Following a lengthy review of numerous Employee Retention Credit ("ERC") claims, the IRS has announced plans to deny tens of thousands of “improper high-risk ERC claims” (about 10-20% of total ERCs) while starting a new round of processing lower-risk claims to help eligible taxpayers. During the review period, the IRS processed 28,000 claims worth $2.2 billion and disallowed more than 14,000 claims worth more than $1 billion. Various estimates of total ERC claims have exceeded $240 billion.

The IRS' review involved months ...

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