The IRS has extended the time periods provided originally in Notice 2016-22 (see earlier coverage in Procedures for Obtaining Work Opportunity Credit Certifications for 2015 and Early 2016 Hires Outlined by IRS) to deal with the extension of the Work Opportunity Credit passed by Congress as part of the Protecting Americans from Tax Hikes Act of 2015.

Now the relief applies to employees hired on or before August 31, 2016 so long as the application is submitted on or before September 28, 2016.

In June the IRS extended the dates for both hiring and applying for certification in Notice 2016-40.

With spring training underway in Arizona (where this author lives), it's appropriate to have a baseball tie in to a tax development, so we turn to one of the great insights given to us by a player of the sport:

“It’s like déjà vu all over again.”

The above quote, attributed to Yogi Berra, is appropriate to the IRS returning again to dealing with the mess left by Congress’s late in 2015 decision to retroactively extend the Work Opportunity Credit. The IRS has issued another notice to “clean up” problems created by Congress’s delay in extending expired code provisions, waiting until late December to pass the Protecting Americans from Tax Hikes Act of 2015 (PATH), just as the Congress did one year earlier. 

In Notice 2016-22 the IRS provided procedures to be used for employers that hired individuals that retroactively qualify as “targeted” individuals during the period where the work opportunity credit under IRC §51 had expired.