David Fuller

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David Fuller focuses his practice on matters involving employee fringe benefits, independent contractor/employee classification, payroll taxes, information reporting, corporate aircraft, supplemental unemployment compensation benefits (SUB Pay), Section 139 qualified disaster relief payments and the contingent workforce (outsourcing, PEOs, and employee leasing). His unique practice includes tax litigation on a wide range of significant FICA and tax refund matters. In the area of SUB Pay plans, David was either the IRS drafting attorney, reviewing manager or the private sector submitter on more than three-fourths of all of the SUB Pay rulings issued by the IRS National Office during the past three decades. Read David Fuller's full bio.

Employers Be Forewarned and Forearmed: Recent IRS Announcements Require Action on ERTC Claims


By and on Nov 8, 2023
Posted In IRS Guidance

Promoters and tax advisors have extensively marketed the Employee Retention Tax Credit (ERTC) as a way for employers to reclaim Federal Insurance Contributions Act payroll taxes paid during the first two years of COVID-19. The rules governing ERTC claims are complex and nuanced, however, resulting in increased scrutiny by the Internal Revenue Service (IRS). Asserting...

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