Extension of limitation on assessment

Notwithstanding section 6501, the limitation on the time period for the assessment of any amount attributable to a credit claimed under this section shall not expire before the date that is 6 years after the latest of—

(A) the date on which the original return which includes the calendar quarter with respect to which such credit is determined is filed,

(B) the date on which such return is treated as filed under section 6501(b)(2), or

(C) the date on which the claim for credit or refund with respect to such credit is made.

(A) In general Notwithstanding section 6511, in the case of an assessment attributable to a credit claimed under this section, the limitation on the time period for credit or refund of any amount attributable to a deduction for improperly claimed ERTC wages shall not expire before the time period for such assessment expires under paragraph (1).

(B) Improperly claimed ERTC wages For purposes of this paragraph, the term “improperly claimed ERTC wages” means, with respect to an assessment attributable to a credit claimed under this section, the wages with respect to which a deduction would not have been allowed if the portion of the credit to which such assessment relates had been properly claimed.