Employee Retention Credit/ERC Archives

Employee Retention Credit/ERC

The Employee Retention Credit: Ninth Circuit affirms denial of injunction, but leaves door open on merits

by Akiva B. Ungar and Edward L. Froelich | Mar 27, 2026 | Appellate Courts, Court Procedure Matters, IRS Appeals, Significant Court Decision, Trial Courts

Case: ERC Today, LLC v. McInelly, Case No. 25-2642 (9th Cir. Mar. 17, 2026)

We previously discussed the US District Court for the District of Arizona’s April 2025 order denying a motion for a preliminary injunction filed by two tax preparation firms challenging the Internal Revenue Services’ (IRS) automated “risking” model for processing Employee Retention Credit (ERC) claims. The firms appealed, and on March 17, 2026, the US Court of Appeals for the Ninth Circuit affirmed the district court’s denial – but the way in which it did so warrants attention.

Standing, but not substance

The Ninth Circuit affirmed on the narrow ground that the tax preparation firms failed to demonstrate Article III standing. The Court found that the firms offered no evidence that they were making less money or spending more on representations because of the IRS’s processing approach. The Court also rejected claims of procedural and reputational injury, holding that IRS administrative procedures are designed to protect taxpayers, not the economic interests of third-party contingency fee firms.

Given the standing ruling, the Court did not address whether the IRS’s Disallowance During Processing program, which uses automated risk models to categorically disallow thousands of claims without individualized review, violates the Administrative Procedure Act or is otherwise unlawful. Those questions remain open. A challenge brought by a party with proper standing could reach those merits and might reveal the program to be infirm.

The future of taxpayer challenges

This decision comes as the IRS closes the book on ERC processing. In February 2026, the IRS announced it had closed all non-examined ERC claims as of December 31, 2025, meaning businesses whose claims were closed without payment must now pursue litigation to secure their refunds.

Unlike the tax preparation firms in ERC Today, taxpayers whose claims have been disallowed can engage the jurisdiction of a refund court under Internal Revenue Code Sections 6532 and 7422 and would have no standing issues. They would be better positioned to test the legality of the IRS’s automated processing procedures on the merits and should consider raising the argument in their complaint. As we have previously cautioned, however, taxpayers must remain vigilant about statutes of limitations: Administrative delay does not eliminate judicial deadlines, and a protest to the IRS Independent Office of Appeals does not suspend the two-year period under Section 6532(a) to file a refund suit.

Is your ERC claim protected? Keep an eye on litigation deadlines

by Akiva B. Ungar, Samuel F. Hamer and Edward L. Froelich | Mar 13, 2026 | Court Procedure Matters, IRS Appeals, IRS Guidance, Tax Refunds, Trial Courts

In February 2026, the Internal Revenue Service (IRS) announced that, as of December 31, 2025, it had closed all non-examined Employee Retention Credit (ERC) claims. This development could compel businesses to pursue litigation to secure their ERC refunds. In its announcement, the IRS also noted that approximately 41,000 claims remain under IRS examination or appeal.

The IRS’s announcement brings renewed focus to a risk we have been highlighting for some time: Statutes of limitation can quietly extinguish otherwise valid refund claims. As discussed in our article in Bloomberg on how to litigate and resolve ERC claims, administrative delay does not eliminate judicial deadlines. For taxpayers whose claims have been formally disallowed, Internal Revenue Code Section 6532(a) provides only two years to file a refund suit. A protest to the IRS Independent Office of Appeals (IRS Appeals) does not suspend that deadline. Without filing suit or obtaining a written extension (Form 907), the right to a refund can be permanently lost.

For taxpayers with ERC claims that are pending without action (i.e., those described in the IRS’s announcement), the statute of limitations analysis is more complex. Some courts have dismissed taxpayer suits that were filed more than six and a half years from the time the claim arose.[1] Under the logic of these cases, there may be a six-and-a-half-year limit in effect from the date a refund claim is filed – the six months a taxpayer must wait before filing a refund suit plus six years during which the government is susceptible to suit under a general statute of limitations on civil claims against the government (31 U.S.C. § 3702(b)). For ERC claims submitted in 2020, the end of this possibly applicable six-and-a-half-year period is quickly approaching. To the extent a court will apply this limitation, a taxpayer with an ERC refund claim may be barred from suit even without a formal disallowance by the IRS.

The message for businesses is consistent with our earlier guidance: Protecting the right to an ERC refund requires a proactive strategy. Taxpayers must identify which limitations periods apply to their claims, manage calendar critical deadlines, and evaluate whether protective litigation is necessary to preserve their potential refunds. Businesses facing challenged, delayed, or disallowed ERC claims should evaluate their statute posture urgently. Our tax controversy & litigation team continues to advise clients on navigating ERC audits, IRS Appeals proceedings, and refund litigation to ensure procedural missteps do not foreclose recovery.

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[1] See Wagenet v. United States, No. CV 08-01234, 2009 WL 4895363, at *5 (C.D. Cal. Sept. 14, 2009) (dismissing tax refund action as filed outside the six-year statute). See also Bowman Transp., Inc. v. United States, 220 Ct. Cl. 36, 40–41 (1979) (interpreting 28 U.S.C. § 2501 and explaining that “[d]espite the fact that the carrier has only two years from the date on which the refund claim is expressly disallowed or apparently the regular six-year period of limitations contained in 28 U.S.C. § [...]

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IRS roundup: June 18 – July 11, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney | Jul 15, 2025 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025.

“One Big Beautiful Bill Act” tax provisions

On July 4, 2025, US President Donald Trump signed the “One Big Beautiful Bill Act” (OBBBA) into law, which enacted several changes to federal tax law. Some of the key changes that affect IRS administration and/or federal tax procedure include:

Form 1099-NEC reporting threshold. The reporting threshold for payments to non-employees for personal services will be raised from $600 to $2,000 beginning in 2026. While amounts below the threshold will still constitute income subject to taxation, an employer will not be subject to backup withholding requirements or be required to issue a Form 1099 if the total value of the services provided cost less than $2,000.
Controlled foreign corporations (CFCs). The look-through rule for CFCs under Internal Revenue Code Section 954 is permanently extended. New Section 951B extends the CFC inclusion rules to “foreign controlled US shareholders” of foreign-controlled CFCs (the US shareholder must own more than 50% by value or vote of the foreign corporation to be designated as such). The tax law also creates a one-month deferral election for determining a CFC’s tax year.
Opportunity zone designation. The OBBBA establishes a permanent opportunity zone policy, maintaining current designation guidelines. For investors with investments made after December 31, 2026, gains deferred via investment in the Qualified Opportunity Zone program will now be recognized on the fifth anniversary of the investment date.

Additionally, the OBBBA introduces a detailed reporting regime as included in new Code Sections 6039K and 6039L. A penalty provision in Code Section 6726 is also included to improve oversight and transparency regarding the economic impact of qualified opportunity investments. The reporting penalties can be as high as $10,000 per return or up to $50,000 for qualified opportunity funds with assets worth more than $10 million. The US Department of the Treasury must publish annual reports on opportunity zone investments and economic performance of the designated tracts.

Employee Retention Credit (ERC) update. Pending ERC claims filed after January 31, 2024, for the third or fourth quarters of 2021 are disallowed under the tax law. The statute of limitations on assessment for ERC (i.e., the period during which the IRS may recapture ERC through assessment) was also extended to six years. The OBBBA also imposes penalties on ERC promoters who fail to comply with due diligence requirements and demonstrate that they did not facilitate the making of fraudulent claims.

IRS guidance

June 23, 2025: The IRS issued Notice 2025-30, publishing the inflation adjustment factor and reference price for calendar year 2025 for the renewable electricity production credit under Code Section 45. The inflation adjustment factor for calendar year 2025 for qualified energy resources is 1.9971, and the reference price for calendar year 2025 for facilities producing electricity from wind is 3.1 cents per [...]

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The Employee Retention Credit: A court challenge to IRS guidance

by Shawn O’Brien, Samuel F. Hamer and Michael J. Scarduzio | Jul 8, 2025 | Court Procedure Matters, IRS Guidance, Trial Courts

Case: Stenson Tamaddon LLC v. IRS, No. CV-24-01123-PHX-SPL, 2025 WL 1725942 (D. Ariz. June 20, 2025)

On June 20, 2025, the US District Court for the District of Arizona denied a motion for summary judgment that was filed by Stenson Tamaddon LLC (StenTam). The tax advisory firm argued that IRS Notice 2021-20, which provided informal guidance on claiming the Employee Retention Credit (ERC), was invalid because it was a “legislative rule” that was not promulgated through notice and comment rulemaking as required by the Administrative Procedure Act (APA). The court ruled that while StenTam had standing to challenge the validity of the notice, the notice was an “interpretive rule” and its issuance as such did not violate the APA. The court also addressed StenTam’s arguments that the Internal Revenue Service (IRS) exceeded its statutory authority in issuing the notice and that it acted in an arbitrary or capricious manner.

Background on the Employee Retention Credit

The ERC was enacted in 2020 as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial relief to businesses affected by the COVID-19 pandemic. Congress’s goal was to incentivize businesses experiencing significant disruptions because of COVID-19-related government orders or a substantial decline in gross receipts to retain employees on payroll and rehire displaced workers. The ERC is calculated as a percentage of qualified wages paid to employees during periods in 2020 and 2021.

Millions of employers have filed refund claims seeking ERC. Since the enactment of the CARES Act, the IRS has issued roughly $269 billion in ERC. However, more than 200,000 claims have been disallowed, reversed, or recaptured, and another 592,000 remain pending as of late April 2025. To the frustration of many, taxpayers whose claims have been processed in 2025 waited an average of more than 18 months before the IRS took action. According to a recent report from the Taxpayer Advocate Service, the IRS will need until at least the end of 2025 to process all remaining ERC claims. However, the IRS may still seek to recapture refunds relating to ERC claims well into the future.

IRS Notice 2021-20

A 102-page document presented in “question-and-answer” format, the IRS published Notice 2021-20 in March 2021 with the intention to “provide[ ] guidance on the [ERC] . . . .” In its suit, StenTam alleged that the notice “defined various terms in Section 3134 [providing for the ERC], identified factors or elements necessary to claim the credit, set minimum thresholds for recovery of ERC, and imposed new, related record-keeping requirements—all of which resulted in the ERC being restricted to a lesser number of businesses than originally contemplated by Congress.” The parties disputed whether the notice created substantive duties and restrictions that carry the force of law. Under the APA, agencies are generally required to follow notice and comment rulemaking procedures before issuing guidance that creates such duties or restrictions.

StenTam’s challenge to Notice 2021-20

StenTam is a tax services firm that advises clients claiming ERC. The firm contended that its business [...]

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“Big, Beautiful Bill”: Federal Tax Bill Would Restrict the Employee Retention Credit

by Shawn O’Brien, Samuel F. Hamer and Michael J. Scarduzio | May 20, 2025 | Tax Reform

A sweeping federal tax bill that is currently under consideration in the US House of Representatives contains provisions that would significantly change the administration and enforcement of the Employee Retention Credit (ERC).

The ERC was enacted in 2020 as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial relief to businesses affected by the COVID-19 pandemic by incentivizing employers to retain employees on payroll and rehire displaced workers. The ERC allowed employers that experienced significant disruptions due to government orders or a substantial decline in gross receipts to claim a tax credit equal to a percentage of qualified wages paid to employees. Millions of employers have filed refund claims seeking ERC for periods in 2020 and 2021. Since the enactment of the CARES Act, the Internal Revenue Service (IRS) has issued roughly $250 billion in ERC. More than 500,000 claims remained pending as of April 2025.

The federal tax bill, dubbed the “Big, Beautiful Bill” by US President Donald Trump, would prevent the IRS from allowing ERC that was claimed by a taxpayer on or before January 31, 2024. The deadline to claim ERC for taxable quarters in 2020 was April 15, 2024, and the deadline to claim ERC for taxable quarters in 2021 was April 15, 2025. The tax bill would thus appear to render ineligible all pending claims that were made after January 31, 2024, which are likely to be considerable in number. The bill is ambiguous as to whether taxpayers who have already been allowed ERC would need to repay those amounts to the extent their claims were made after January 31, 2024.

The tax bill would also extend the statute of limitations on the IRS’s ability to assess amounts attributable to ERC. Presently, the IRS has three years to assess amounts associated with ERC for all periods in 2020 and for Q1 and Q2 of 2021. The IRS has five years to assess amounts associated with ERC for Q3 and Q4 of 2021. The proposed legislation would extend both of these limitations periods to six years. This change would be significant, especially because the IRS is authorized to assess and collect erroneously allowed ERC by notice and demand.

Practice Point: Taxpayers with pending ERC claims should be alert to ongoing legislative developments – as this area continues to be a prominent focus of federal tax policy – and prepare now to defend ERC claims (even those filed after the potentially new deadline of January 31, 2024). Enactment of the changes proposed in the tax bill could dramatically restrict the amount of ERC currently eligible to be paid or credited and may empower the IRS to recapture a greater amount of claims already allowed. But considerable uncertainties remain as to the scope of the changes proposed in the bill. In the face of this uncertainty, taxpayers should consult experienced counsel who can assist them in preparing to defend ERC claims to which they are entitled.

The Employee Retention Credit: IRS’s “Risking” Model Faces Legal Challenge

by Shawn O’Brien, Samuel F. Hamer and Michael J. Scarduzio | Apr 24, 2025 | 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 automated “risk assessment model” that the IRS used to evaluate and disallow claims for the Employee Retention Credit (ERC), seeking to restore individualized review of ERC claims.

BACKGROUND ON THE ERC

The ERC was enacted in 2020 as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial relief to businesses affected by COVID-19 by incentivizing employers to retain employees and rehire displaced workers. The ERC allowed employers that experienced significant disruptions due to government orders or a substantial decline in gross receipts to claim a tax credit equal to a percentage of qualified wages paid to employees. Millions of employers have filed amended employment tax returns (Form 941-X) claiming the credit for periods in 2020 and 2021. Since the enactment of the CARES Act, the IRS has issued roughly $250 billion in ERC.

THE IRS’S MORATORIUM AND AUTOMATED RISK ASSESSMENT MODEL

In September 2023, the IRS instituted a moratorium on processing ERC claims to review its procedures, reduce the backlog of claims, and identify potential fraud. Before the moratorium, all ERC claims received individualized review. During the moratorium, the IRS developed an automated “risk assessment model” to facilitate the processing of claims. This model, which is alternatively known as “risking,” utilizes taxpayer-submitted data and publicly available information to predict the likelihood that a taxpayer’s claim is valid or invalid. Claims deemed to be “high risk” by the system are excluded from review by an IRS employee and instead are designated for immediate disallowance. In August 2024, the IRS lifted its ERC processing moratorium and began issuing thousands of disallowance notices to taxpayers. Notwithstanding these actions, the number of pending ERC claims remained above one million as of November 2024.

THE COURT CHALLENGE TO THE IRS’S “RISKING” MODEL

In their motion for a preliminary injunction, filed January 7, 2025, the plaintiffs (the tax preparation firms) sought a court order compelling the IRS to, among other things, stop the use of “risking” and restore individualized employee review of ERC claims. The plaintiffs claimed to be injured by the “risking” model because they were unable to collect contingency fees from clients when claims were disallowed.

In support of their motion, the plaintiffs pointed to having received on behalf of their clients many boilerplate rejections immediately following the end of the moratorium. The plaintiffs alleged that these summary disallowances were arbitrary and capricious, thus violating the Administrative Procedure Act (APA), because the “risking” model precluded the IRS from acquiring information necessary to properly evaluate the claims.[1] The plaintiffs also contended that the disallowances reflected a shift in IRS policy to disfavor ERC, with the result being that several legitimate claims were being [...]

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DOJ Announces Largest Employee Retention Credit Fraud Indictment

by Michael J. Scarduzio, Samuel F. Hamer and Edward L. Froelich | Jan 28, 2025 | 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 and SFLC programs were designed to help businesses retain employees on the payroll during the COVID-19 pandemic. Prosecutors allege that the defendants exploited these programs by submitting fraudulent claims on behalf of ineligible businesses, inflating employee numbers, and misrepresenting wages. DOJ asserted that the defendants concealed their involvement by not identifying themselves as preparers on the returns, using virtual private networks and through other means.

Practice Point: DOJ’s announcement makes clear that ERC fraud remains an enforcement priority for 2025. Taxpayers and tax professionals should prepare now to defend their ERC claims, including by compiling and maintaining substantiation to support each claim, and be ready to take immediate steps should they receive an IRS audit notice, a request for documentation or information, or are otherwise contacted by the government.

Weekly IRS Roundup June 17 – June 21, 2024

by Evan Walters, Kevin Spencer and Sama Kaseer | Jun 27, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17, 2024 – June 21, 2024.

June 17, 2024: The IRS released Internal Revenue Bulletin 2024-25, which includes the following:

Revenue Ruling 2024-12, which provides the June 2024 applicable federal rates.
Treasury Decision 9993, which provides final regulations on the election under Internal Revenue Code (Code) 6418 to transfer eligible energy credits, effective July 1, 2024.
Treasury Decision 9997, which reduces the cost of applying for or renewing a preparer tax identification number from $21 to $11.
Proposed Regulations, which would remove the “associated property rule” and related rules from the regulations on interest capitalization requirements for improvements to “designated property” under Code 263A(f) and clarify the definition of “improvement” in the existing regulations.

June 17, 2024: The IRS announced the establishment of a new dedicated group within the Office of Chief Counsel that will focus on developing guidance for partnerships, specifically with respect to the use of “basis shifting” transactions by related-party partnerships.

June 17, 2024: The IRS released guidance intended to target certain transactions that use the basis adjustment provisions in Code §§ 734, 743, 754 and 755 to shift basis to depreciable property through partnership transactions. This guidance includes:

Revenue Ruling 2024-14, which identifies three types of basis shifting transactions involving related parties that, according to the IRS, should be disallowed for lack of economic substance.
Notice 2024-54, which announces the IRS’s intent to propose regulations under Code §§ 732, 734, 743 and 755 that, if finalized, are intended to take effect on or after June 17, 2024. The regulations would identify several types of “covered transactions” in which basis step-ups resulting from partnership transactions would be disallowed. Unlike Revenue Ruling 2024-14, these regulations would not depend on a covered transaction lacking economic substance.
Proposed Regulation § 1.6011-18, which would identify certain partnership basis shifting transactions as “transactions of interest,” which generally must be disclosed to the IRS.

June 17, 2024: The IRS provided general tips for taxpayers benefiting from educational assistance programs under Code § 127 with respect to the treatment of certain educational expenses, qualified education loans and working condition fringe benefits.

June 17, 2024: The IRS released Notice 2024-53, which provides the 24-month average corporate bond segment rates for June 2024, yield curve and segment rates for single-employer plans and 30-year Treasury securities interest rates.

June 18, 2024: The IRS announced the release of final regulations for taxpayers who satisfy certain prevailing wage and apprenticeship (PWA) requirements regarding the construction, alteration or repair of certain clean energy facilities or properties, projects or equipment. Taxpayers who satisfy these PWA requirements are eligible for increased credit or deduction amounts for certain clean energy [...]

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Weekly IRS Roundup May 13 – May 17, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | May 24, 2024 | 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 May 13, 2024 – May 17, 2024.

May 13, 2024: The IRS released Internal Revenue Bulletin 2024-20, which includes proposed regulations concerning the excise tax on stock buybacks under § 4501 of the Internal Revenue Code (Code). The proposed regulations are generally consistent with the guidance previously provided in Notice 2023-2. The proposed regulations also include guidance on reporting and payment of the Code § 4501 excise tax.

May 14, 2024: The IRS announced that, contrary to recent reports, there will be no changes to Native American tribes’ access to federal tax payment offsets through state arrangements.

May 14, 2024: The IRS reminded US citizens and resident aliens living abroad to file and pay their taxes.

May 14, 2024: The IRS warned taxpayers not to fall for inaccurate social media advice and tax scams centered around the Fuel Tax Credit, the Sick and Family Leave Credit and household employment taxes that led taxpayers to file inflated refund claims during the 2023 tax season.

May 14, 2024: The IRS released census tract geographic identifiers that are eligible for Code § 30C using 2015 and 2020 delineations of census tract boundaries, which can be accessed at Appendix A and Appendix B, respectively.

May 15, 2024: The IRS reminded businesses to check their tax returns for signs of incorrect Employee Retention Credit (ERC) claims and listed signs that an ERC claim could be incorrect.

May 15, 2024: The IRS released Notice 2024-42, which specifies updated static mortality tables for defined benefit pension plans under Employee Retirement Income Security Act of 1974 (ERISA) provisions for valuation dates occurring during the 2025 calendar year. The notice also includes a modified unisex version of the mortality tables for determining minimum present values under ERISA for distributions with annuity starting dates that occur during stability periods beginning in the 2025 calendar year.

May 15, 2024: The IRS released Revenue Ruling 2024-12, which provides the June 2024 applicable federal rates.

May 15, 2024: The IRS released Notice 2024-40, which provides the 24-month average corporate bond segment rates for May 2024, the yield curve and segment rates for single-employer plans and the 30-year Treasury securities interest rates.

May 16, 2024: The IRS released Notice 2024-41, which modifies Section 3.04 of Notice 2023-38 by revising the contents of the “Applicable Projects” list. The notice also provides a safe harbor under which taxpayers may elect to qualify for the domestic content bonus credit. Learn more here.

May 16, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Ohio that [...]

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Weekly IRS Roundup March 25 – March 29, 2024

by Kevin Spencer, Evan Walters and Jeremy Kass | Apr 2, 2024 | 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 March 25, 2024 – March 29, 2024.

March 25, 2024: The IRS released Internal Revenue Bulletin 2024-13, which includes the following:

Notice 2024-28, which invites the public to submit items they want included in the 2024-2025 Priority Guidance Plan. The Priority Guidance Plan identifies and prioritizes the tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.
Revenue Procedure 2024-11, which provides general rules and specifications from the IRS for paper and computer-generated substitutes for Form 941, Schedule B (Form 941), Schedule D (Form 941), Schedule R (Form 941) and Form 8974.
Proposed regulations, which would modify existing regulations to allow certain unincorporated organizations that are organized exclusively to produce electricity from certain property to be excluded from the application of partnership tax rules.

March 25, 2024: The IRS announced that almost 940,000 people across the nation have unclaimed refunds for tax year 2020 and face a May 17 deadline to submit their tax returns.

March 25, 2024: The IRS released the transcript of Commissioner Danny Wefel’s one-year anniversary speech.

March 25, 2024: The IRS reminded taxpayers they can access a free recording of the 2023 Form 1099-K webinar, which provides important info for tax professionals and anyone who receives a Form 1099-K, including people who use popular payment apps and online marketplaces.

March 25, 2024: The IRS announced that individuals and businesses in the Wrangell Cooperative Association of Alaska Tribal Nation that were affected by severe storms, landslides and mudslides that began on November 20, 2023, now have until July 15, 2024, to file various federal individual and business tax returns and make tax payments.

March 25, 2024: The IRS released Notice 2024-32, which provides guidance on the eligibility of loan borrowers through State Supplemental Loan programs and the loan size limitation for State Supplemental Loans. The notice also provides guidance on whether an issue of state or local bonds, the proceeds of which are used to finance or refinance qualified student loans (as defined in § 1.150-1(b)) or to finance qualified mortgage loans (as defined in § 1.150-1(b)), is a refunding issue.

March 26, 2024: The IRS released Announcement 2024-16, which provides general information on advance pricing agreements and the Advance Pricing and Mutual Agreement Program.

March 26, 2024: The IRS reminded taxpayers filing 2023 tax returns that they must check a box indicating whether they received digital assets as a reward, award, or payment for property or services or disposed of any digital asset that was held as a capital asset through a sale, exchange or transfer.

March 27, 2024: The IRS announced that the previous February 15, 2024, [...]

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