IRS Drops and Detonates Bomb: Notice 2021-49

Out of the blue, 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, IRS attempts to blow away the landscape by opining that more than 50% C or S Corp shareholder’s wages sometimes don’t count as ERC qualifying wages. But, irony of ironies, sometimes such wages do qualify.

Is IRS’s new unsolicited opinion correct? That is for a court(s) of law to decide one day. The tens of thousands of dollars question on the table: What do we do next? Do we accept the new altered landscape or challenge IRS’s puzzling new stance? If challenge, how do we do so?

Highlights:

• IRS launches long-awaited guidance on PPP, SVOG and RRG effect on gross receipts
• Breaking down IRS’s new Notice 2021-49
• A naked look at the statutory language that created the “owner wage” controversy
• IRS’s unsolicited view of the owner wage controversy – Some 50% owner wages count, others left out in the cold
• IRS launches long-awaited guidance on PPP, SVOG and RRG effect on gross receipts
• Approaches in response and consequences
• Punch list of ERC items IRS did (or did not) clean up
• New lay of the land for recovery startup businesses – This one is huge
• Into the fray of ARPA’s new 3Q and 4Q ERC
• The latest on potential Congressional meddling

Presenter: Bradley Burnett

Bradley Burnett, J.D., LL.M., is a practicing Colorado tax attorney with 33 years of tax practice experience.  His practice emphasis is on tax planning and tax controversy resolution.  He also prepares a handful of tax returns.

Mr. Burnett has delivered more than 3,000 presentations on U.S. tax law throughout all fifty U.S. states, Washington, D.C., the Bahamas, Italy, Greece, Turkey, and Canada. He has authored texts of 35 CPE courses.  He has appeared on television answering tax questions for call-in viewers of Denver NBC affiliate KUSA Channel 9.  Brad received the Illinois Society of CPAs Instructor Excellence Award for teaching in Chicago and five times has been the top-rated, most requested instructor for CPA Society annual tax conferences.

Burnett’s seminar style is to deliver the subject matter in briskly paced, enthusiastic and witty fashion.  His forte’ is the candid communication of practical ideas relating to tax law.

Host: Rick Telberg

• Founder and CEO CPA Trendlines, Bay Street Group
• Accounting Today Top 100
• CPA Practice Advisor Top 25

Host: Sandi Leyva

• Founder and President Accountant’s Accelerator, Sandra L Leyva, Inc.
• CPA Practice Advisor Top 25
• Most Powerful Women in Accounting