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 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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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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Weekly IRS Roundup December 30, 2024 – January 3, 2025
By Kevin Spencer, Evan Walters and Samuel F. Hamer on Jan 13, 2025
Posted In 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 December 30, 2024 – January 3, 2025. December 30, 2024: The IRS released Internal Revenue Bulletin 2025-1, which includes the following: Revenue Procedure 2025-1, which contains the revised procedures for letter rulings and information letters issued...
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