The U.S. IRS recently issued guidance on the retroactive termination of the Employee Retention Credit effective from 1 October 2021, unless the employer is a "recovery startup business", in which case the ERC terminates from 1 January 2022. The ERC was previously available for qualified wages paid before 1 January 2022 in general, but this was limited by the Infrastructure Investment and Jobs Act, enacted on 15 November 2021.
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IRS issues guidance regarding the retroactive termination of…