Proposed Legislation Could Impact Financial Services Company ERC Filings

Legislation released by the House Ways and Means Committee last week proposes a number of changes, notably a provision that would end ERC filing substantially earlier than the initial deadline. This would limit the ability for financial services companies who have not yet filed to claim the credit. Under this proposal, all claims (2020 and 2021 credits) would need to be submitted by January 31, 2024, in order to be eligible for processing.

Currently, the deadlines for filing are:

  • 2020 claims: Due April 15, 2024
  • 2021 claims: Due April 15, 2025

This legislation is currently only proposed, but all organizations currently working through ERC eligibility, calculations, or 941X preparation should be aware of this proposed change and the potential timeline.

See additional details in this recently released CLA article and stay tuned for updates as we have them.

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Dean has more than 25 years of experience providing audit, internal audit, and consulting services to financial services companies. He has provided consulting services in the areas of business lending, product costing and profitability, and asset/liability management. Dean has worked with a number of financial services companies on strategic issues such as board governance and enterprise risk management, as well as the role of internal audit and risk management, regulatory issues, and many accounting related topics.

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