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IRS provides new flexibility in reporting ERC income adjustments

By Tonya Rule and Gil Mitchell
March 25, 2025
IRS Building and Sign

Key Takeaways

  • Dealing with delayed ERC approvals - and denials.

The IRS has quietly made a big change in how taxpayers claiming Employee Retention Credits reduce their deductions for payroll expense. 

Taxpayers will no longer be required to amend a prior year income tax return or file an administrative adjustment request (AAR) to adjust the wage expense as a result of an Employee Retention Credit claim, under changes included in an updated FAQ last week.

Instead, Taxpayers can report the adjustment as gross income on the income tax return in the year the ERC payment is received. Before this guidance was released, taxpayers had to reduce their wage expense for any credits taken in the year the wage expense was incurred. For example, for an ERC claimed for 2020, wage expense for 2020 would need to be reduced. 

The new guidance also gives ERC claimants an option: if the statute of limitations has not closed, taxpayers can amend a prior year tax return to reduce their wage expense by the amount of the ERC claimed, or they can instead include the credit in gross income on the tax return when it is received. If the statute has closed for amending the prior return and the taxpayers have not made the required deduction adjustment, they should report the ERC as gross income in the year it is received.  The IRS warns in the FAQs that by not recognizing the ERC on a tax return, Taxpayers “may be claiming an unwarranted double benefit”.

If the IRS disallows an ERC claim, the FAQ allows taxpayers to increase their wage expense in the year the disallowance is final, after the taxpayer has given up efforts to receive the credit.

Contact Gil Mitchell or Tonya Rule with questions.

Related: How to Account for the Employee Retention Credit

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About the Author(s)

Tonya Rule

Tonya M. Rule, CPA

Partner/Affordable Care Act Practice Leader
Tonya helps businesses with the rules surrounding the Affordable Care Act. She assists large employers with the compliance requirements, Forms 1094-C and 1095-C, and she also advises them on very technical rules that many employers and advisors aren't aware of. In addition, she works with small businesses who are planning on expanding their current operations to make sure they are doing everything from measuring their employees correctly to deciding on the best insurance plan for their business. Tonya regularly works with clients on various ACA IRS notices and has been very successful in getting most of these penalties abated.
Gil Mitchell Photo

Gil Mitchell, EA

Senior Manager
Gil helps our clients by using his 36 years of IRS examination experience to guide each examination or tax controversy to the best possible solution. Gil's main focus today is leading the firm's Employee Retention Credit Controversy (ERC) Team to resolve our clients issues with both ERC examinations and unpaid claims.

Material discussed is meant to provide general information and it is not to be construed as specific investment, tax or legal advice. Keep in mind that current and historical facts may not be indicative of future results. This is meant for educational purposes only. Information presented should not be considered investment advice or a recommendation to take a particular course of action. Always consult with a financial professional regarding your personal situation before making any financial decisions.