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MMARCH

Client Alert: Nonprofits in the Crosshairs: DOJ Targets PPP Loans Under the Civil False Claims Act

THE HIGHLIGHTS FOR NONPROFITS RECEIVING DOJ LETTERS

 
  • On May 27, 2026, the U.S. Attorney's Office for the District of Columbia announced civil False Claims Act settlements with two nonprofits over PPP loans they were not eligible to receive, totaling more than $450,000.
  • The Department of Justice (DOJ)'s new National Fraud Enforcement Division, announced April 7, 2026, signals that pandemic-relief recoveries against nonprofits are accelerating, not winding down.
  • A nonprofit that received a DOJ letter, a civil investigative demand or an SBA inquiry about PPP eligibility faces civil exposure of up to treble damages plus a per-claim penalty.

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ARTICLE

Client Alert: Kwong and the July 10 Deadline: Why Advisors Should Flag Protective Refund Claims This Week

  • For most affected taxpayers, a protective claim on Form 843 must be filed by July 10, 2026 to preserve the right to a refund
  • The IRS has formally accepted only a narrow 60-day postponement, so claims relying on the full period should be filed protectively and may have to be litigated
  • Kwong v. United States treats federal tax deadlines that fell between January 20, 2020 and July 10, 2023 as postponed, opening a path to recover penalties and interest paid during the COVID-19 disaster period

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ARTICLE

Client Alert: 2026 Health Care Fraud Takedown Includes Virginia and a Renewed Focus on Medicaid Cases

On June 23, 2026, the Department of Justice announced the 2026 National Health Care Fraud Takedown, which it described as the largest coordinated health care fraud enforcement action in its history. The aggregate figures are substantial: charges against 455 defendants, including roughly 90 doctors and other licensed professionals, tied to more than $6.5 billion in allegedly false claims. The action spanned 56 federal districts and 45 states and territories and, notably, drew the participation of 50 state Medicaid Fraud Control Units, which is the most the Department has ever assembled for a single takedown. 

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