The Employee Retention Credit (ERC) continues to be a significant factor for U.S. businesses. With the recent news release from the IRS, it is clear that the IRS does not plan to refund a majority of the claims and those that will be processed will be done at a "dramatically slower" pace. In this course, Matt Kelley and Tim Parrish from Resolute Tax Credits will be joined by Tom Cullinan from Chamberlain Hrdlicka to discuss ERC IRS audit activity, how taxpayers should interpret the recent IRS release, and a strategy to use litigation to process an ERC claim.
Learning Objectives:
Matt Kelley has over 17 years of experience as a tax attorney working with Fortune 100 clients on complex tax matters as well as serving small businesses in securing valuable tax benefits. Matt spent most of his career with Ernst & Young LLP where he served as the market leader for EY's Northeast Region Workforce Services Practice. In the past 10 years, Matt has focused on supporting clients on federal and state tax incentives, employment tax matters, and federal tax incentives such as the Employee Retention Credit, Work Opportunity Tax Credit, the federal R&D tax credit, and the federal Opportunity Zone program. He has spoken on tax topics to audiences including the American Bar Association, the G-20 Young Entrepreneur's Summit, CPA tax conferences, the US Chamber of Commerce, and similar organizations.
Resolute Tax Credits
Co-Founder
tim.parrish@resolutetaxcredits.com
(469) 842-0163
Prior to founding Resolute, Tim co-led Ernst & Young LLP's tax credits practice. As a licensed attorney, he has over ten years' experience building tax credit and incentives services, managing business requirements for proprietary tax technology, monitoring and consulting on proposed tax legislation, and advising companies of all sizes on tax savings opportunities. In recognition of his efforts during the height of the pandemic, Tim was named a finalist for EY's Mike Boldasaro Exceptional Client Service Award.
Throughout his career, Tim has helped hundreds of clients with programs such as the Work Opportunity Tax Credit, Federal Empowerment Zone Credit, COVID-19 and Disaster Employee Retention Credits, Tips Credit, Child Care Credit, Paid Family and Medical Leave Credit, and state and local discretionary incentives and hiring credits.
Chamberlain Hrdlicka
Shareholder
tom.cullinan@chamberlainlaw.com
(404) 658-5421
Tom Cullinan is a Shareholder in the Firm's Atlanta office. Tom joined the Firm from the IRS, where he served as the Counselor to the IRS Commissioner and then as the acting IRS Chief of Staff.
While at the IRS, Tom was a member of the Commissioner’s core leadership team, and he advised the IRS Commissioner on the most critical issues facing the agency, including the IRS strategic plan and budget, staffing, internal operations, enforcement of tax laws and service to taxpayers. He was particularly involved in high-level enforcement issues. Among other things, Tom either conceived or helped launch the Office of Fraud Enforcement, the Office of Promoter Investigations, and the Joint Strategic Emerging Issues Team, all of which should be key IRS enforcement tools in the coming years. Tom also helped implement various policies pertaining to cryptocurrencies and served as an invited IRS representative to several Financial Stability Oversight Council meetings regarding cryptocurrencies.
Before joining the IRS, Tom spent twenty years as a tax attorney representing taxpayers in tax controversy matters. He has represented hundreds of taxpayers, including low-income individuals in pro bono matters, high net-worth individuals, partnerships, trusts and estates, and corporations in IRS audits, administrative appeals, and litigation, on a wide variety of tax issues often with significant amounts at issue. Tom pursues every possible opportunity to resolve tax disputes and is adept at negotiating acceptable resolutions. Yet, litigation is sometimes inevitable and he has a notable track record in that regard.
Tom works in the Firm’s tax controversy practice where he draws on both his extensive background representing taxpayers and his deep knowledge of the IRS organization, operations, and procedures.
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