Hale E. Sheppard

Shareholder @ Chamberlain Hrdlicka | Tax Controversy | Litigation Attorney | International Tax Chairman

[Hale E. Sheppard @HaleESheppard]

The IRS normally must identify non-compliance within a short period, which can be tricky if the relevant matters occurred abroad. This article, using several recent Tax Court cases as a springboard, examines three tools at the IRS’…https://t.co/c62SBVjzZr https://t.co/CqI0XY6cFi

[Hale E. Sheppard @HaleESheppard]

This article provides an overview of Section 179D, identifies the related Compliance Campaign, explains the aggressive position recently taken by the IRS about allocation of Section 179D deductions, and analyzes a list of authoriti…https://t.co/nPqp7wgket https://t.co/vQEOF7TxdU

[Hale E. Sheppard @HaleESheppard]

The IRS conducts large numbers of audits, the period to complete them is limited, and tax issues are becoming more complex every year. The result is that some Revenue Agents employ aggressive tactics to gather data and prepare repo…https://t.co/yZe6aMHJGC https://t.co/q6rd0HWAlp

[Hale E. Sheppard @HaleESheppard]

A recent Tax Court case, Toulouse v. Commissioner, partially resolves the question of whether U.S. individuals can use foreign tax credits to offset net investment income taxes, while expressly leaving open the possibility of diffe…https://t.co/Zslr08W49r https://t.co/9JVvHcB7MM

[Hale E. Sheppard @HaleESheppard]

The mechanism for achieving the elusive double victory of defeating the IRS and then obligating the IRS to pay legal, accounting, expert and other fees is found in Section 7430. This article describes key aspects of fee recoupment under Section 7430. https://t.co/jr1cF0WPHA

[Hale E. Sheppard @HaleESheppard]

Several recent cases demonstrate that the IRS is “stacking” penalties imposing multiple sanctions against the same taxpayer, for the same year, in connection with the same problem. The article explains common U.S. international tax…https://t.co/caemucWMzV https://t.co/HVuFd2GaoZ

[Hale E. Sheppard @HaleESheppard]

Section 7345 authorizes the IRS, with assistance from the State Department, to deprive individuals with serious tax debts of their passports. This article does the “heavy lifting” for readers by gathering, organizing and analyzing…https://t.co/iUPx2OuBtP https://t.co/Tu8e2DqJrq

[Hale E. Sheppard @HaleESheppard]

U.S. taxpayers living, investing or doing business abroad often form corporations in the local country for legitimate reasons. The problem is not establishing the corporations, but rather maintaining full compliance with the IRS thereafter. https://t.co/nar08c8omS

[Hale E. Sheppard @HaleESheppard]

Those concerned about taxpayer rights, separation of powers, environmental protection and other large-scale matters might question whether numerous “wrongs” by the IRS are achieving a “right.” #ConservationEasement #SCETs https://t.co/OnU4AQ6FKK

[Hale E. Sheppard @HaleESheppard]

This article analyzes a recent Tax Court case, Crandall v. Commissioner, using it as a springboard for learning important lessons about the effect of Closing Agreements with the IRS, unique steps in rectifying international tax iss…https://t.co/8GVn7zsrqW https://t.co/PuIPb83l72

[Hale E. Sheppard @HaleESheppard]

Some taxpayers facing large IRS liabilities assume they can escape unharmed if they can just keep the IRS at bay until they die or if they simply move their assets abroad. These theories sound good, but they are wrong. This article…https://t.co/Vm05h2Inzo https://t.co/KzL8dGBVQN

[Hale E. Sheppard @HaleESheppard]

All matters involved with #conservationeasement donations are complex, and the settlement initiative is no exception https://t.co/wRwIPcgI9d

[Hale E. Sheppard @HaleESheppard]

#InternationalTax disputes sometimes trigger three disputes, occurring in three different venues, and resulting in three potentially large liabilities https://t.co/qVRoOFI9sO

[Hale E. Sheppard @HaleESheppard]

The IRS takes the stance that any error or omission in connection with Form 8283, regardless of how minor, merits a deduction of $0 #conservationeasement https://t.co/sa8UTvzdzv

[Hale E. Sheppard @HaleESheppard]

Conservation easements, partners, and qualified amended returns. #conservationeasement #QualifiedAmendedReturns https://t.co/sqH6y6ZJFM

[Hale E. Sheppard @HaleESheppard]

Taxpayers die but their international penalties survive. #FBAR #IntlTax
https://t.co/t5b74JSN04

[Hale E. Sheppard @HaleESheppard]

Depriving Partnerships of Access to the Independent Office of Appeals:  Old and New IRS Challenges to Conservation Easements. https://t.co/6agiCNQt0S

[Hale E. Sheppard @HaleESheppard]

The critical role of notifications by Tax Matters Partners in conservation easement disputes #conservationeasement https://t.co/bbQZEtkGip

[Hale E. Sheppard @HaleESheppard]

Court overturns legendary FBAR case, Bedrosian, but settlements elsewhere encourage taxpayers with foreign account violations. #FBAR #IntlTax https://t.co/ZTj3f3R52Q

[Hale E. Sheppard @HaleESheppard]

Harsh Consequences of Late Forms 1120-F, New Tax Court Case, and Solutions Still Available to Foreign Corporations.  #Form1120F https://t.co/RkVvm2VnIf