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IRS Creates Open-Ended Potential Liability Exposure for Employer 4980H Penalties
Troutman Sanders 
[Guidance Overview] Mar. 9, 2020 "Although it remains to be seen if or how aggressively the IRS will attempt to pursue ESRPs for returns filed more than three years ago, ALEs should not assume that they are, at any time, 'in the clear' for such years but should instead be prepared to pay or challenge an ESRP with respect to any calendar year beginning with 2015." |
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