Samuel F. Hamer
Subscribe to Samuel F. Hamer's PostsSamuel (Sam) F. Hamer focuses his practice on US and international tax matters. Read Sam Hamer's full bio.
IRS Roundup May 2 – May 13, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on May 19, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 2, 2025 – May 13, 2025. IRS GUIDANCE May 2, 2025: The IRS issued Revenue Procedure 2025-20, providing guidance on the domestic asset/liability percentages and domestic investment yields used by foreign life insurance companies and foreign property and...
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IRS Roundup April 1 – April 17, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on May 1, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2025 – April 17, 2025. April 4, 2025: The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan...
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The Employee Retention Credit: IRS’s “Risking” Model Faces Legal Challenge
By Shawn O’Brien, Samuel F. Hamer and Michael J. Scarduzio on Apr 24, 2025
Posted In Court Procedure Matters, IRS Appeals, Trial Courts
Case: ERC Today LLC et al. v. John McInelly et al., No. 2:24-cv-03178 (D. Ariz.) In an April 2025 order, the US District Court for the District of Arizona denied a motion for a preliminary injunction filed by two tax preparation firms. The firms sought to halt the Internal Revenue Service’s (IRS) use of an...
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The Employee Retention Credit: How to Litigate and Resolve Claims
By Shawn O’Brien, Michael J. Scarduzio and Samuel F. Hamer on Apr 10, 2025
Posted In IRS Appeals
The Employee Retention Credit (ERC) was designed to help employers keep their employees on payroll during the COVID-19 pandemic by offering a refundable tax credit against certain employment taxes. Despite the Internal Revenue Service (IRS) issuing more than $242 billion in ERC as of early 2025, the processing and payment of these claims have faced...
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IRS Roundup March 15 – March 28, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio, Matthew J. Blaney and Parisa M. Griess on Apr 7, 2025
Posted In IRS Guidance, Tax Reform, Transfer Pricing Resource
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing the April 2025 short-, mid-, and long-term applicable federal rates for purposes of Internal Revenue Code Section 1274(d), as well...
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Upcoming Webinar: Navigating IRS Tax Refunds
By Shawn O’Brien, Susan E. Ryba and Samuel F. Hamer on Mar 31, 2025
Posted In Tax Refunds
On April 9, 2025, join McDermott’s Tax Controversy & Litigation Group for an insightful webinar on the intricacies of claiming and collecting Internal Revenue Service (IRS) tax refunds. This session is designed for tax professionals, legal practitioners, and anyone interested in understanding the complexities of the IRS refund claims process and what to watch out...
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IRS Roundup February 17 – March 14, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Mar 14, 2025
Posted In IRS Guidance
Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition in recent weeks and issued significantly less guidance than normal. We did not publish the IRS Roundup regularly during these weeks as...
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FedEx Defeats Government’s Loper Bright Gambit
By Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Evan Walters on Mar 13, 2025
Posted In Court Procedure Matters, IRS Guidance, Tax Refunds
On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings are earnings from a taxpayer’s profitable related foreign corporations that are offset by losses from other related foreign corporations. FedEx...
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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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