Michael J. Scarduzio
Subscribe to Michael J. Scarduzio's PostsMichael J. Scarduzio focuses his practice on US and international tax matters, particularly civil and criminal tax litigation. From audit to litigation, he represents taxpayers in all phases of tax controversy, including novel issues of first impression such as financial hedging transactions using a captive insurer, US tax implications of a foreign master-feeder fund’s investment activities and matters arising under Internal Revenue Code (IRC) Sections 7216 and 7212(a). Read Michael Scarduzios full bio.
IRS Roundup February 10 – 14, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Feb 25, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS The previous IRS Roundup provided general coverage of the proposed Taxpayer Assistance and Service (TAS) Act. This post highlights Section 310 of the TAS Act, which would...
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IRS Roundup January 20 – 31, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Feb 13, 2025
Posted In Court Procedure Matters, IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS January 22, 2025: The IRS reminded taxpayers that they have rights – outlined in the Taxpayer Bill of Rights – any...
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IRS Roundup January 13 – 17, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Feb 4, 2025
Posted In Alternative Dispute Resolution, IRS Appeals, IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS January 15, 2025: The US Department of the Treasury (Treasury) and the IRS published final regulations, providing guidance on the resolution of federal tax controversies by...
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DOJ Announces Largest Employee Retention Credit Fraud Indictment
By Michael J. Scarduzio, Samuel F. Hamer and Edward L. Froelich on Jan 28, 2025
Posted In Uncategorized
On January 22, 2025, the US Department of Justice (DOJ) announced the indictment of seven individuals in the largest Employee Retention Credit (ERC) fraud scheme to date. According to the indictment, the defendants filed more than 8,000 refund claims for ERCs and Sick and Family Leave Credits (SFLCs), totaling more than $600 million. The ERC...
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IRS Roundup January 6 – 10, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Jan 22, 2025
Posted In IRS Audits, IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6, 2025 – January 10, 2025. January 6, 2025: The IRS released Internal Revenue Bulletin 2025-2, which includes Announcement 2025-2. The announcement states that, if finalized, certain portions of proposed regulations on required minimum distributions...
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