The One Big, Beautiful Bill (OBBB) enacted on July 4, 2025 changed the rules for Employee Retention Credit (ERC) claims filed after January 1, 2024. Recently, the Internal Revenue Service (IRS) issued a Fact Sheet with answers to frequently asked questions (FAQs) about the revised rules. 

The Internal Revenue Service (IRS) recently announced that it is launching a two-year pilot program under its existing Post Appeals Mediation (PAM) procedure. According to the IRS, this pilot program should make PAM “more attractive to taxpayers,” and the Director of the IRS’ ADR Program Management Office has stated that he anticipates the pilot program will lead to more negotiated resolutions following unsuccessful appeals. Here are some insights for taxpayers who may be considering PAM from Washington D.C. tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group: