Out of the blue, the IRS has exploded onto the scene with Notice 2021-49.  What does it do?  It not only defines the world as we’ll know it for the 3Q and 4Q 2021 ERC, but also . . .   
 
In a huge, unexpected move, the IRS attempts to blow away the landscape by opining that more than 50% C or S Corp shareholder wages sometimes don’t count as ERC qualifying wages. But, irony of ironies, sometimes such wages do qualify.
 
Is the IRS’s new unsolicited opinion correct? That is for a court(s) of law to decide one day. The question on the table that’s worth tens of thousands of dollars: What do we do next? Do we accept the new altered landscape or challenge the IRS’s puzzling new stance? If we challenge, how do we do so?


Course Highlights:

• Long-awaited IRS guidance on PPP, SVOG, and RRG effect on gross receipts


• The latest on potential congressional meddling


• New lay of the land for recovery startup businesses—This one is huge!


• The IRS’s unsolicited view of the owner wage controversy—Some 50% owner wages count, others left out in the cold

• Evaluate the IRS’s new Notice 2021-49


• Identify the statutory language that created the “owner wage” controversy


• Express approaches in response and consequences


• Outline the punch list of ERC items the IRS did (or did not) clean up


• Determine the new lay of the land for recovery startup businesses