Top 5 Tax Benefits to Battle COVID-19 Impacts
Client Alert | 3 min read | 04.02.20
The past two weeks have seen many important tax changes coming out of Washington. Crowell & Moring, LLP has been following these developments carefully and issuing Tax Alerts to keep our clients and friends informed of changes in the tax laws and at the IRS. In this Tax Alert, we highlight our “Top Five” tax developments, which businesses should be considering as they weather the COVID-19 crisis. We will be discussing these issues in our upcoming webinar on Friday, April 3.
1. Payroll Tax Credits & Payments – We will focus on the Payroll Deposit provisions and the Employee Retention Credit. We have summarized these provisions here and the IRS already has issued some guidance on these provisions, as well as a form to facilitate advance payment. Click here, here, and here for the related IRS FAQs.
2. The Corporate Tax Changes – We will review the various changes and highlight how the modifications to the rules relating to NOL carrybacks and the interest limitation deductions interact with the international tax provisions of the TCJA such as the repatriation provisions, BEAT, FDII, and GILTI. Click here to read a summary of the corporate tax changes.
3. IRS Procedures Regarding Audits and Enforcement – We will discuss recent IRS announcements regarding filing extensions, IDRs, and signatures as well as tips for managing tax audits during the COVID-19 shutdown as summarized here. Congress appropriated $250 million to the IRS to cover the extended filing season and implementation of COVID-19 changes.
4. The Implications of Remote Work – We will examine the potential federal tax issues related to effectively connected income and permanent establishments as well as the potential state tax issues relating to how to properly allocate employee income.
5. The Next Wave – We will offer our thoughts on the possible additional tax changes in future legislation and the potential IRS administrative action in response to the COVID-19 crisis, including assistance to specific industries, such as traditional and alternative energy and hospitality.
As noted above, Crowell & Moring, LLP’s Tax Group will be presenting a Webinar on April 3 at 1:00 EDT to discuss the key provisions of the COVID-19 legislation affecting businesses, changes to IRS audit and collection procedures, and additional tax changes that may be in the next wave of legislation. You may register for the Webinar by clicking here.
We anticipate potential tax changes in the next wave of legislation aimed at inoculating the economy from COVID-19 and are monitoring stimulus programs being considered. We will provide periodic updates on our Coronavirus Resource Center.
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Client Alert | 3 min read | 11.21.25
On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future.
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