Michael Scarduzio

Michael J. Scarduzio focuses his practice on US and international tax matters, particularly civil and criminal tax litigation. From audit to litigation, he represents taxpayers in all phases of tax controversy, including novel issues of first impression such as financial hedging transactions using a captive insurer, US tax implications of a foreign master-feeder fund’s investment activities and matters arising under Internal Revenue Code (IRC) Sections 7216 and 7212(a). Read Michael Scarduzio's full bio.
The Employee Retention Credit: How to Litigate and Resolve Claims
By Shawn O’Brien, Samuel Hamer and Michael Scarduzio on Apr 10, 2025
Posted In Employee Benefits, Employment
The Employee Retention Credit (ERC), introduced under the Coronavirus Aid, Relief, and Economic Security Act in March 2020, was designed to help employers retain employees during the COVID-19 pandemic by offering a refundable tax credit against certain employment taxes. However, the processing and payment of ERC claims have faced significant delays, with many claims remaining...
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DOJ Announces Largest Employee Retention Credit Fraud Indictment
By Michael Scarduzio, Samuel Hamer, Edward Froelich and Shawn O’Brien on Feb 11, 2025
Posted In Employee Benefits
On January 22, 2025, the US Department of Justice announced the indictment of seven individuals in the largest Employee Retention Credit fraud scheme to date. According to the indictment, the defendants filed more than 8,000 refund claims for ERCs and Sick and Family Leave Credits, totaling more than $600 million. Read more here.
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