Practice Areas

Education

University of Kansas, B.S., with distinction

University of Kansas, M.A., with honors

University of Kansas, J.D.

Universidad de Chile, LL.M., with highest distinction

University of Florida, LL.M.T., graduate tax scholar

Honors

Best Lawyers in America® - Tax Law, 2025

Best Lawyers in America® - Litigation & Controversy - Tax, 2025

American College of Tax Counsel, Fellow (2019 through 2022)

Chambers USA - Tax Litigation Leader (2009 through 2022)

Georgia Super Lawyers - Tax (2012 through 2024)

Best Lawyers in America - Tax Litigation and Controversy (2019 through 2024)

Best Lawyers in America - Lawyer of the Year in Tax and Tax Litigation and Controversy in Atlanta, 2023

Legal 500 – Tax Litigation and Controversy (2015 through 2022)

Bar Admissions

Georgia Bar

Florida Bar

Texas Bar

Washington, D.C. Bar

Court Admissions

U.S. Tax Court

U.S Court of Federal Claims

U.S. Court of International Trade

U.S. Court of Appeals, Federal Circuit

U.S. Court of Appeals, 4th Circuit

U.S. Court of Appeals, 11th Circuit

U.S. District Court, Middle District of Georgia

U.S. District Court, Northern District of Georgia

Profile

Practice Areas

Hale Sheppard is a partner in the Tax Controversy Section of Chamberlain Hrdlicka. He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues. Hale's practice focuses on the following:

Overview of Practice Areas
- Tax audits
- Tax administrative appeals
- Tax Court litigation
- Tax refund claims and litigation
- Private letter rulings
- International tax disputes, compliance, and planning
Common Domestic Tax Matters

Conservation easement disputes
Micro-captive insurance disputes
Employee Retention Credit disputes
Paycheck Protection Program loan treatment disputes
Virtual currency or cryptocurrency disputes
Opportunity Zone disputes
SECA taxes and “limited partner” exception disputes
Midco or intermediary transactions disputes
Section 179D energy efficient commercial building deduction disputes
The “Ultimate Plan” or “Ultimate Tax Plan” disputes
Research Tax Credit disputes
Charitable Remainder Annuity Trust disputes
Monetized installment sale disputes
Puerto Rico residency and Act 22 disputes
Section 199A qualified business income deduction disputes
R&D tax credit disputes
Tax shelter promoter disputes
Reportable transaction disputes
Material advisor disputes
Worker-classification disputes
Passive activity loss disputes
Reasonable compensation disputes
Family office disputes
Trust fund recovery disputes
Hobby loss disputes
Bad debt loss disputes

Common International Tax Matters

Repatriation / transition tax disputes under Section 965
Foreign retirement plan disputes
Private placement life insurance disputes
Malta pension disputes
Foreign bank account, FinCEN Form 114, FBAR disputes
Foreign trust disputes (Form 3520 and Form 3520A)
Foreign gift disputes
Foreign tax credit disputes
Treaty-based return position disputes (Form 8833)
Expatriation / exit tax disputes
Foreign earned income exclusion disputes
International tax withholding disputes
Foreign investment in real property tax act disputes
Passport revocation disputes
Tax disputes involving EB-5 investors
Voluntary disclosure programs and related disputes

Tax Litigation

Most tax disputes are resolved during the audit or with the Appeals Office. However, if taxpayers cannot reach a reasonable settlement, litigation ensues. Hale has participated in the following cases before the Tax Court, District Courts, and Federal Courts of Appeal:

129-134 Biltmore Ave. Properties, LLC v. Commissioner, Tax Court Docket 28864-21
2909 Peachtree Place, LLC v. Commissioner, Tax Court Docket No. 31173-21
2909 Peachtree Place, LLC v. Commissioner, Tax Court Docket No. 643-22
A.I. Enterprises, Inc. v. Georgia Dept. of Revenue, OSAH-REV-SUTA-1026268-60
Alabama S&G, LLC v. Commissioner, Tax Court Docket No. 7703-19
Albero Holdings, LLC v. Commissioner, Tax Court Docket No. 16284-21
Albert v. Commissioner, Tax Court Docket No. 8108-19
Ancient Oaks Holdings, LLC v. Commissioner, Tax Court Docket No. 2538-24
Anderson Holllow, LLC v. Commissioner, Tax Court Docket No. 12154-23
Appleby v. Commissioner, Tax Court Docket No. 20592-05
Argent TH A, LLC v. Commissioner, Tax Court Docket No. 29514-21
Argent TH A, LLC v. Commissioner, Tax Court Docket No. 227-22
Asheville Star Building Owner, LLC v. Commissioner, Tax Court Docket No. 28867-21
Asper v. Commissioner, Tax Court Docket No. 14456-08
Astroturf Construction Corporation v. Commissioner, Tax Court Docket No. 17630-23
Atkinson v. Commissioner, Tax Court Docket No. 20377-08
Aycox v. Commissioner, Tax Court Docket No. 3125-17
Aycox v. Commissioner, Tax Court Docket No. 3126-17
Azar v. Commissioner, Tax Court Docket No. 18450-15
Backwater Bluff Holdings, LLC v. Commissioner, Tax Court Docket No. 13011-24
Baltimore v. Commissioner, Tax Court Docket No. 24592-07
Barnes Escambia Properties, LLC v. Commissioner, Tax Court Docket No. 7097-19
Bayou Sand Acquisitions, LLC v. Commissioner, Tax Court Docket No. 12864-21
Be Creek, LLC v. Commissioner, Tax Court Docket No. 7417-19
Bear Creek LH Holdings, LLC v. Commissioner, Tax Court Docket No. 12236-20
Bear Creek LKB Holdings, LLC v. Commissioner, Tax Court Docket No. 16378-21
Bear Creek SK Holdings, LLC v. Commissioner, Tax Court Docket No. 12400-20
Bear Creek SK Holdings, LLC v. Commissioner, Tax Court Docket No. 14140-20
Bello v. Commissioner, Tax Court Docket No. 191-22
Bickford Farm, LLC v. Commissioner, Tax Court Docket No. 18981-22
Bickford Farm, LLC v. Commissioner, Tax Court Docket No. 22943-22
Bird Granite, LLC v. Commissioner, Tax Court Docket No. 3431-23
Blythe v. Georgia Dept. of Revenue, Georgia Tax Tribunal, Docket No. 2438175
Boatwright v. Commissioner, Tax Court Docket No. 9669-24
Bonaventura v. Commissioner, Tax Court Docket No. 732-07
Boyd Granite Holdings, LLC v. Commissioner, Tax Court Docket No. 3959-24
Briggs v. Commissioner, Tax Court Docket No. 5738-19
Broad River Hardwoods, LLC v. Commissioner, Tax Court Docket No. 5477-24
Brookside Valley Investments, LLC v. Commissioner, Tax Court Docket No. 3368-23
Brookwood Properties, LLC v. Commissioner, Tax Court Docket No. 7170-24
Browndale Plantation Reserve, LLC v. Commissioner, Tax. Court Docket. No. 20378-21
Brushy Hollow, LLC v. Commissioner, Tax Court Docket No. 12644-20
Burn Creek Farms, LLC v. Commissioner, Tax Court Docket No. 635-23
Byrd v. Commissioner, Tax Court Docket No. 19218-07
Callaway Creek, LLC v. Commissioner, Tax Court Docket No. 3970-24
Carr v. Commissioner, Tax Court Docket No. 14192-11
Carspecken v. Commissioner, Tax Court Docket No. 6168-05
Cash Dollar Cove, LLC v. Commissioner, Tax Court Docket No. 12427-23
Cedar Falls Property v. Commissioner, Tax Court Docket No. 9209-24
Cedar Grove Property, LLC v. Commissioner, Tax Court Docket No. 14286-24
Cedar Land, LLC v. Commissioner, Tax Court Docket No. 7284-19
Centurion Georgia, LLC v. Commissioner, Tax Court Docket No. 18139-23
Chattahoochee River Holdings, LLC v. Commissioner, Tax Court Docket No. 11476-23
Clark v. Commissioner, Tax Court Docket No. 26201-10
Colavito v. Commissioner, Tax Court Docket No. 28650-14
Cole Quarry, LLC v. Commissioner, Tax Court Docket No. 11953-23
Collinsville Land, LLC v. Commissioner, Tax Court Docket No. 12022-20
Collinsville Land, LLC v. Commissioner, Tax Court Docket No. 12644-20
Contreras Torres v. Commissioner, Tax Court Docket No. 6063-19
Cotton Hill Holdings, LLC v. Commissioner, Tax Court Docket No. 6419-23
Country Wood Lane, LLC v. Commissioner, Tax Court Docket No. 12206-23
Crimson Independence, LLC v. Commissioner, Tax Court Docket No. 11561-20
Crockett 941, LLC v. Commissioner, Tax Court Docket No. 13767-20
Crowder v. Commissioner, Tax Court Docket No. 18095-11
Cub Creek Preserve, LLC v. Commissioner, Tax Court Docket No. 12401-20
Curtis Investment Company, LLC v. Commissioner, T.C. Memo 2017-150
Day Road Holdings, LLC v. Commissioner, Tax Court Docket No. 12888-23
Deems v. Commissioner, Tax Court Docket No. 13054-06
Deep Creek, LLC v. Commissioner, Tax Court Docket No. 7283-19
Delta Sand Acquisitions, LLC v. Commissioner, Tax Court Docket 12364-20
Denny Pines, LLC v. Commissioner, Tax Court Docket 5124-24
DG Mineral Reserve, LLC v. Commissioner, Tax Court Docket 12403-23
Dilworth v. Alabama Dept. of Revenue, Alabama Tax Tribunal Docket No. 22-873-JP
Dixie Land Real Estate, LLC v. Commissioner, Tax Court Docket No. 6267-24
Dixon v. Commissioner, Tax Court Docket, No. 24439-09
Eades Rock, LLC v. Commissioner, Tax Court Docket No. 3433-23
East Fork Investment Group, LLC v. Commissioner, Tax Court Docket 10944-21
Edwards v. Commissioner, Tax Court Docket No. 4480-08
Elk Horn Investment Group, LLC v. Commissioner, Tax Court Docket No. 10195-23
Elliott v. Commissioner, Tax Court Docket No. 18282-23
Emory v. Commissioner, Tax Court Docket No. 21467-11
Entrekin v. Commissioner, Tax Court Docket No. 13512-09
Equity Investment Associates, LLC v. United States, W.D. NC, Case 3:21-cv-170f
Equity Investment Associates, LLC v. Commissioner, Tax Court Docket No. 11973-23
Espy v. Georgia Dept. of Revenue, Georgia Tax Tribunal Docket No. 2317524
Estate of Heilwig Beckers v. Commissioner, Tax Court Docket No. 3123-22
Estate of Mularoni v. Commissioner, Tax Court Docket No. 17822-21
Estate of Mularoni v. Commissioner, Tax Court Docket No. 18613-21
Excelsior Aggregates, LLC v. Commissioner, Tax Court Docket No. 20608-18
Figure 8 (Georgia), LLC v. Commissioner, Tax Court Docket No. 30608-21
Figure 8 (Highlands), LLC v. Commissioner, Tax Court Docket No. 29850-21
Flint River Oaks, LLC v. Commissioner, Tax Court Docket No. 11473-23
Flomaton Pits, LLC v Commissioner, Tax Court Docket No. 7636-19
Foster v. Commissioner, Tax Court Docket No. 14907-08
Foster v. Commissioner, Tax Court Docket No. 25101-13
Friedman v. Commissioner, Tax Court Docket No. 24219-14
Geiger OSCP3, LLC. v. Commissioner, Tax Court Docket No. 019587-17
Generostee Shoals, LLC v. Commissioner, Tax Court Docket 7200-24
Ginn Creek, LLC v. Commissioner, Tax Court Docket No. 12644-20
Goddard v. Commissioner, Tax Court Docket No. 13513-17
Goodwater Gap, LLC v. Commissioner, Tax Court Docket No. 3651-24
Graham v. Commissioner, Tax Court Docket No. 17876-08
Gray Mountain, LLC v. Commissioner, Tax Court Docket No. 21354-21
Great Plains, LLC v. Commissioner, Tax Court Docket No. 7304-19
Greenbriar Land Holdings, LLC v. Commissioner, Tax Court Docket No. 8268-23
Greer Building, LLC v. Commissioner, Tax Court Docket No. 12153-23
Guerrero v. Commissioner, Tax Court Docket No. 6193-23
Gullickson v. Commissioner, Tax Court Docket No. 22478-22
Hackney Creek, LLC v. Commissioner, Tax Court Docket No. 2148-24
Hancock County Land, LLC v. Commissioner, Tax Court Docket No. 12385-20
Hancock County Land, LLC v. Commissioner, Tax Court Docket No. 12649-20
Hargrave v. Commissioner, Tax Court Docket No. 24316-14
Harp v. Commissioner, Tax Court Docket No. 28603-10
Heartland Automotive v. United States, 10 AFTR 2d 2009-2406
HEC II Assurance, Inc. v. Commissioner, Tax Court Docket No. 20423-23
Hendrick v. Commissioner, Tax Court Docket No. 8805-08
Henry Eagle Brook 223, LLC v. Commissioner, Tax Court Docket No. 8703-24
Herrera v. Commissioner, Tax Court Docket No. 21709-08
Hiers v. Commissioner, Tax Court Docket No. 19277-17
Hiers v. Commissioner, Tax Court Docket No. 16338-19
Highland Lake, LLC v. Commissioner, Tax Court Docket No. 25988-21
Highland Lake, LLC v. Commissioner, Tax Court Docket No. 27483-21
Highland Property Holdings, LLC v. Commissioner, Tax Court Docket No. 8778-23
Highway 20 Henry 74, LLC v. Commissioner, Tax Court Docket No. 3733-23
Hildebrandt Owner, LLC v. Commissioner, Tax Court Docket No. 13866-23
Hill Top S&G, LLC v. Commissioner, Tax Court Docket No. 7704-19
Hillside Holdings, LLC v. Commissioner, Tax Court Docket No. 12890-20
Hillside Holdings, LLC v. Commissioner, Tax Court Docket No. 13452-20
Hilton v. Commissioner, Tax Court Docket No. 2459-19
Hogan v. Commissioner, Tax Court Docket No. 17280-10
Hoyes v. Commissioner, Tax Court Docket No. 21911-19
Housing Associates of Frisco, LP v. Commissioner, Tax Court Docket No. 21780-11
Illuminate Resources, LLC v. Commissioner, Tax Court Docket No. 34894-21
Industrial S&G, LLC v. Commissioner, Tax Court Docket No. 7475-19
Jake Hollow Holdings, LLC v. Commissioner, Tax Court Docket No. 4760-24
JC Land, LLC v. Commissioner, Tax Court Docket No. 7360-19
Jones Meadow, LLC v. Commissioner, Tax Court Docket No. 6064-24
Kesterton v. Commissioner, Tax Court Docket No. 9878-22
Kight v. Commissioner, Tax Court Docket No. 12249-14
King v. Commissioner, Tax Court Docket No. 11897-14
Kissinger Acquisitions, LLC v. Commissioner, Tax Court Docket No. 1440-23
Knat Creek, LLC v. Commissioner, Tax Court Docket No. 7637-19
Laakso v. Commissioner, Tax Court Docket No. 21912-19
Lake Jordan Holdings, LLC v. Commissioner, Tax Court Docket No. 16532-21
Lakepoint Land II, LLC v. Commissioner, Tax Court Docket No. 13925-17
Landow v. Commissioner, T.C. Memo 2011-177
Legacy Louisville, LLC v. Commissioner, Tax Court Docket No. 12146-23
Leroque v. Commissioner, Tax Court Docket No. 13253-09
Little Generostee Creek, LLC v. Commissioner, Tax Court Docket No. 18936-23
Little Horse Creek Property, LLC v. Commissioner, Tax Court Docket No. 7421-19
Little Newford Creek, LLC v. Commissioner, Tax Court Docket No. 1915-24
Little Pumpkin Creek North, LLC v. Commissioner, Tax Court Docket No. 12717-20
Little Pumpkin Creek North, LLC v. Commissioner, Tax Court Docket No. 14143-20
Little River Preserve, LLC v. Commissioner, Tax Court Docket No. 15880-23
Lockhart v. Commissioner, Tax Court Docket No. 17809-06
Loesel and McDougall v. Commissioner, Tax Court Docket No. 14453-12
Long Branch Land, LLC v. Commissioner, Tax Court Docket No. 7288-19
Long Leaf Property Holdings, LLC v. Commissioner, Tax Court Docket No. 11982-16
Lookout Creek Mining Co., LLC v. Commissioner, Tax Court Docket No. 3906-21
Louisiana Motion Picture Credit Fund v. Commissioner, Tax Court Doc. No. 1256-11
LVI Investors, LLC v. Commissioner, T.C. Memo 2009-254
Magnolia West, LLC v. Commissioner, Tax Court Docket No. 6924-23
Massey Creek, LLC v. Commissioner, Tax Court Docket No. 816-24
Mathias v. Commissioner, Tax Court Docket No. 10124-06
McAlister v. Commissioner, Tax Court Docket No. 18584-08
McGovern v. Commissioner, Tax Court Docket No. 8145-09
McLeod v. Commissioner, Tax Court Docket No. 12676-21
McNorthup Properties, LLC v. Commissioner, Tax Court Docket No. 28861-21
MDH Timber Holdings, LLC v. Commissioner, Tax Court Docket No. 6929-24
Meadowwood Financial Services, LLC v. Commissioner, Tax Docket No. 18630-17
Mill Creek 770, LLC v. Commissioner, Tax Court Docket No. 12251-20
Miller v. Commissioner, Tax Court Docket No. 24376-1
Mingledorff v. Commissioner, Tax Court Docket No. 7804-22
Mingledorff v. Commissioner, Tax Court Docket No. 9508-22
Mingledorff v. Commissioner, Tax Court Docket No. 9510-22
Mingledorff Subtrust v. Commissioner, Tax Court Docket No. 9509-22
Mingledorff Subtrust v. Commissioner, Tax Court Docket No. 9511-22
Miniyar v. Commissioner, Tax Court Docket No. 18278-23
Mississippi Sand Acquisitions, LLC v. Commissioner, Tax Court Document 12379-20
Moister v. Commissioner, Tax Court Docket No. 7420-19
Montgomery-Alabama River, LLC v. Commissioner, Tax Court Docket No. 9254-19
Moody v. Commissioner, Tax Court Docket No. 12675-21
Moore v. Commissioner, Tax Court Docket No. 15204-19
Mossy Flats Property, LLC - Tax Court Docket No. 11538-24
Mountaineer Equity Holdings, LLC v. Commissioner, Tax Court Docket No. 6423-23
Movie Ranch Alvaton, LLC v. Commissioner, Tax Court Docket No. 5479-24
Mundy v. Commissioner, Tax Court Docket No. 13500-08
Murray v. Georgia Dept. of Revenue, OSAH-REV-ITA-0904170-60
Myers v. Commissioner, Tax Court Docket No. 21188-11
Nautical Hill Holdings, LLC v. Commissioner, Tax Court Docket No. 11971-20
Neighbors Ridge, LLC v. Commissioner, Tax Court Docket No. 12075-23
Nicholson Land Acquisitions, LLC v. Commissioner, Tax Court Docket No. 21953-22
Nobile v. Commissioner, Tax Court Docket No. 24541-12
Nolen Lake, LLC v. Commissioner, Tax Court Docket No. 1936-24
Norma Dean I, LLC v. Commissioner, Tax Court Docket No. 21351-21
Norma Dean I, LLC v. Commissioner, Tax Court Docket No. 29516-21
Norman W. Fries, Inc. v. Commissioner, Tax Court Docket No. 3439-12
Northshore, LLC v. Commissioner, Tax Court Docket No. 11511-21
Oak Ridge Acquisitions, LLC v. Commissioner, Tax Court Docket No. 18916-24
Octagon Glade Family, LLC v. Commissioner, Tax Court Docket No. 34904-21
Old Paris Landing Holdings, LLC v. Commissioner, Tax Court Docket No. 12887-20
Old Paris Landing Holdings, LLC v. Commissioner, Tax Court Docket No. 13453-20
ORC Partners, LLC v. Commissioner, Tax Court Docket No. 1041-16
Oxbow Bend, LLC v. Commissioner, Tax Court Docket No. 12718-19
Parkerson Church Reserve, LLC v. Commissioner, Tax Court Docket No. 11868-20
Parkerson Sands, LLC v. Commissioner, Tax Court Docket No. 25891-21
Parkerson Sands, LLC v. Commissioner, Tax Court Docket No. 32566-21
Perez v. Commissioner, Tax Court Docket No. 24434-09
Patel Educational Services, Inc. v. Commissioner, Tax Court Docket No. 1265-23
Pettis v. Commissioner, Tax Court Docket No. 21335-12
Picayune Pearl Aggregates, LLC v. Commissioner, Tax Court Docket No. 7045-19
Pines & Quail, LLC v. Commissioner, Tax Court Docket No. 1524-23
Piton Holdings, LLC v. Commissioner, Tax Court Docket No. 637-23
Point of the River, LLC v. Commissioner, Tax Court Docket No. 12049-19
Porter House, LLC v. Commissioner, Tax Court Docket No. 31165-21
Porter House, LLC v. Commissioner, Tax Court Docket No. 646-22
Possum Rock, LLC v. Commissioner, Tax Court Docket No. 22637-22
Possum Rock Plantation, LLC v. Commissioner, Tax Court Docket No. 14006-23
Power v. Commissioner, Tax Court Docket No. 18135-11
Pratt v. Commissioner, Tax Court Docket No. 10380-24
Pratt v. Commissioner, Tax Court Docket No. 10803-24
Pratt v. Commissioner, Tax Court Docket No. 11144-24
RLP Holdings, v. Commissioner, Tax Court Docket No. 10190-08
Railroad Valley Mining Corporation v. Commissioner, Tax Court Docket 13683-20
Railroad Valley Mining Corporation v. Commissioner, Tax Court Docket 172-21
Redwood Land Preservation, LLC v. Commissioner, Tax Court Docket No. 8706-24
Rivershore Sand Acquisitions, LLC v. Commissioner, Tax Court Docket No. 126-24
Riverview Land Preservation, LLC v. Commissioner, Tax Court Docket No. 10054-24
Robinson Laurel Partnership v. Commissioner, Tax Court Docket No. 2455-13
Robles v. Commissioner, Tax Court Docket No. 9725-13
Rock Bottom BBS, LLC v. Commissioner, Tax Court Docket No. 9145-21
Rock Cove Property, LLC v. Commissioner, Tax Court Docket No. 6848-24
Roddy Gap, LLC v. Commissioner, Tax Court Docket No. 11451-23
Rosenfeld v. Commissioner, Tax Court Docket No. 11838-12
S&S Nursery, Inc. v. Commissioner, Tax Court Docket No. 12920-11
Salt River Acquisitions, LLC v. Commissioner, Tax Court Docket No. 10062-24
Sanctuary at Falling Creek, LLC, Tax Court Docket No. 11745-24
Sand Investment Co., LLC v. Commissioner, 157 T.C. 11 (2021)
Sandlapper Hill, LLC v. Commissioner, Tax Court Docket No. 31175-21
Santos v. Commissioner, Tax Court Docket No. 19669-23
Savage Point Properties, LLC v. Commissioner, Tax Court Docket No. 14607-23
Savannah Preserve, LLC v. Commissioner, Tax Court Docket No. 16230-24
Savannah Shoals, LLC v. Commissioner, Tax Court Docket No. 3412-22
Scarbrough v. Commissioner, Tax Court Docket No. 9516-24
Schoen v. Commissioner, Tax Court Docket No. 449-10
Schwartz v. Commissioner, Tax Court Docket No. 12531-06
Sehorsch v. Commissioner, Tax Court Docket No. 18612-22
Selman v. Commissioner, Tax Court Docket No. 5917-12
Seven Hawks, LLC v. Commissioner, Tax Court Docket No. 809-22
Sheehan v. Commissioner, Tax Court Docket No. 20850-15
Shofner v. Commissioner, Tax Court Docket No. 5065-11
Silver Run Holdings, LLC v. Commissioner, Tax Court Docket No. 10457-21
Silver Run Holdings, LLC v. Commissioner, Tax Court Docket No. 12660-21
Simmons v. Commissioner, Tax Court Docket No. 5058-06
Smith Lake v. Commissioner, Tax Court Docket No. 004980-17
Smith Woods, LLC v. Commissioner, Tax Court Docket No. 18502-24
Southland Aggregate, LLC v. Commissioner, Tax Court Docket No. 2148-2
Sparta Beef, LLC v. Commissioner, Tax Court Docket No. 16519-23
Sparta Beef, LLC v. Commissioner, Tax Court Docket No. 19736-23
Spartan Investors I, LLC v. Commissioner, Tax Court Docket No. 8579-23
Statler Cleveland, LLC v. Commissioner, Tax Court Docket No. 15231-24
Stillwater Springs Partners, LLC v. Commissioner, Tax Court Docket No. 13838-23
Storey Hollow, LLC v. Commissioner, Tax Court Docket No. 12648-20
Storm Crow, LLC v. Commissioner, Tax Court Docket No. 7190-23
Stringer v. Commissioner, Tax Court Docket No. 15898-07
Swan v. Commissioner, Tax Court Docket No. 29465-08
Sweet Gravy Preservation, LLC, Tax Court Docket No. 11977-24
Tarpon Creek, LLC v. Commissioner, Tax Court Docket No. 1119-23
Tatham Rock Land, LLC v. Commissioner, Tax Court Docket No. 17563-23
Taylor v. Commissioner, Tax Court Docket No. 9121-24
Teague v. Commissioner, Tax Court Docket No. 9478-21
Teague v. Commissioner, Tax Court Docket No. 566-23
Tensaw Creek, LLC v. Commissioner, Tax Court Docket No. 12755-23
Terpstra v. Commissioner, Tax Court Docket No. 12825-10
Thomas v. Commissioner, Tax Court Docket No. 13479-17
Thomas v. Commissioner, Tax Court Docket No. 21689-18
Tigers Eye Trading, LLC v. Commissioner, 138 T.C. No. 6 (2012)
Tivoli Center Chattanooga, LLC v. Commissioner, Tax Court Docket No. 14575-23
Tom’s Mountain Creek, LLC v. Commissioner, Tax Court Docket No. 12210-21
Top Rock BBS, LLC v. Commissioner, Tax Court Docket No. 9152-21
Topping v. Commissioner, T.C. Memo 2007-92
Truax v. Commissioner, Tax Court Docket No. 12399-20
Tsui v. Commissioner, Tax Court Docket No. 26343-12
United States v. Bucari, Case No. 1:21-CV-2199 (N.D. Ga.)
United States v. Drillmann, Case No. 8:18-cv-00830 (M.D. Fla.)
Valley Park Ranch, LLC v. Commissioner, Tax Court Docket No. 12384-20
Valley Park Ranch Two, LLC v. Commissioner, Tax Court Docket No. 11448-23
Veribest Haynie, LLC v. Commissioner, Tax Court Docket No. 4844-23
Veribest Palmetto, LLC v. Commissioner, Tax Court Docket No. 5760-23
Veribest Vesta, LLC v. Commissioner, Tax Court Docket No. 9158-23
Veribest Stevens, LLC v. Commissioner, Tax Court Docket No. 1440-23
Vines v. Commissioner, 126 T.C. 279 (2006)
Vintage at Mt. Vernon, LP v. Commissioner, Tax Court Docket No. 15973-10
Virginia Historic Tax Credit Fund v. Commissioner, T.C. Memo 2009-295
Wahoo River, LLC v. Commissioner, Tax Court Docket No. 503-23
Walnut Gorge, LLC v. Commissioner, Tax Court Docket No. 17123-24
Wasson v. Commissioner, Tax Court Docket No. 8108-09
Waterfork Holdings, LLC v. Commissioner, Tax Court Docket No. 8080-24
Wayside Hill, LLC v. Commissioner, Tax Court Docket No. 16542-23
Weller v. Commissioner, Tax Court Docket No. 28236-08
Whitetail Land Preservation, LLC v. Commissioner, Tax Court Docket No. 13131-24
Winnemucca Holdings, LLC v. Commissioner, Tax Court Docket No. 13938-23
Woods v. Commissioner, Tax Court Docket No. 12230-15
Woods v. Commissioner, Tax Court Docket No. 12231-15
Woods & Water Properties v. Commissioner, Tax Court Docket No. 11913-23
Wright v. Commissioner, Tax Court Docket No. 5491-10
Wrigley v. Commissioner, Tax Court Docket No. 19796-21
Yacht Creek, LLC v. Commissioner, Tax Court Docket No. 504-23
Zolessi v. Commissioner, Tax Court Docket No. 8530-23

IRS Administrative Rulings

In addition to resolving tax disputes, Hale also has considerable experience obtaining favorable rulings for clients from the IRS National Office. A partial list of rulings is set forth below:

Private Letter Ruling _______-24 (ruling regarding Qualified Opportunity Zone certification of eligibility and tax-benefit election)
Private Letter Ruling _______-23 (ruling regarding an Electing Small Business Trust election necessitated by inadvertent termination of S corporation status)
Private Letter Ruling 107742-23 (ruling regarding late election to treat domestic entity as a subchapter S corporation)
Private Letter Ruling 107890-22 (ruling regarding a late portability election of the deceased spousal unused exclusion to decrease U.S. estate taxes)
Private Letter Ruling 121241-21 (ruling regarding late aggregation election under Section 469 concerning rental real properties)
Private Letter Ruling 117191-20 (ruling regarding late election to treat domestic entity as a subchapter S corporation).
Private Letter Ruling 129360-19 (ruling regarding carryover of loss from natural disaster to prior year under Section 165(i))
Private Letter Ruling 119920-19 (ruling regarding reclassification of domestic entity from subchapter S corporation to partnership).
Private Letter Ruling 101685-19 (ruling regarding a late portability election of the deceased spousal unused exclusion to decrease U.S. estate taxes)
Private Letter Ruling 107887-17 (ruling regarding refund methodology involving accounting firm, foreign real estate funds, and non-resident alien investors)
Private Letter Ruling 107272-17 (ruling regarding late Section 754 election and tiered-partnership structure)
Private Letter Ruling 107273-17 (ruling regarding late Section 754 election and tiered-partnership structure)
Private Letter Ruling 101616-17 (ruling regarding a retroactive election, pursuant to Section 877A, to expatriate from the United States without payment of “exit tax”)
Private Letter Ruling 137767-16 (ruling regarding proposed refund methodology, Section 6695(f), and Circular 230)
Private Letter Ruling 131079-14 (ruling regarding potential penalties related to refund methodology for foreign investors in U.S. entities)
Private Letter Ruling 201408003 (ruling authorizing parent corporation to make a late “S” election and to treat two subsidiaries as QSubs)
Private Letter Ruling 201338014 (ruling regarding multiple foreign retirement accounts and special treatment under bilateral treaty)
Private Letter Ruling 201309001 (ruling regarding foreign pension, investment, and other accounts)
Private Letter Ruling 201308003 (ruling addressing various international tax non-compliance issues)
Private Letter Ruling 201242004 (ruling regarding international tax issues concerning foreign retirement plans)
Private Letter Ruling 201210009 (ruling allowing taxpayer to rectify tax non-compliance related to Canadian registered retirement savings plan)
Private Letter Ruling 201131017 (ruling granting taxpayer an extension under 9100 regulations to make favorable international tax election)
Private Letter Ruling 201149014 (ruling concerning special five-year net operating loss carryback rules)
Private Letter Ruling 201002030 (ruling allowing taxpayer to make multi-year election to resolve international tax issues on a penalty-free, tax-free basis)
Private Letter Ruling 200751012 (ruling granting taxpayer relief from back taxes, interest, and penalties resulting from nondisclosure of foreign retirement accounts)

Other Administrative Remedies with IRS

In situations where obtaining a private letter ruling from the IRS National Office is unnecessary, Hale has achieved the desired tax results for clients through other administrative procedures, including the following:

Request pursuant to Rev. Proc. 2008-27 for relief from tax withholding obligation on the disposition of a U.S. real property interest under Treas. Reg. §1.445-2(d)(2).
Request to file late Forms 1120-F (enclosing Form 5472, Forms 8833 , and other international information returns) on a penalty-free basis, claiming all deductions and credits, pursuant to special wavier procedures under Reg. §l.882-4(a)(3)(ii).
Request for extension of the period to obtain "qualified replacement property" and to continue deferring gain after an involuntary conversion, pursuant to Section 1033(a)(2) (B)(ii) and Reg. § l.1033(a)-2(c)(3).
Request for late election to defer U.S. income tax on accretion in foreign retirement plans pursuant to Rev. Proc. 2014- 55.
Request for extension to make an election under Proc. 2009- 52 to carry back net operating losses beyond the normal two-year limit.
Request to make a foreign earned income exclusion election under Section 911 pursuant to Reg. § 1.911-7.
Request to nullify previous election under Section 6013(g) to have non-resident alien spouse treated as U.S. person.
Request for relief to file a late Gain Recognition Agreement under Section 367 and Treas. Reg. § 1.367(a)-8(p) in connection with a foreign-to-foreign reorganization.
Request for elimination of expatriation/exit tax under Section 877A pursuant to the Relief Procedures for Certain Former Citizens.
Request to make a late aggregation election for real estate professionals under Section 469 pursuant to Rev. Proc. 2011-34
Request for penalty waivers related to tax returns and various international information returns pursuant to Notice 2022-36.

Tax Publications

Hale ranks among the most active tax writers in the country, having published more than 280 major articles in top law reviews and tax journals. A partial list of his articles is set forth below.

Exploring Four Recent IRS Enforcement Campaigns on Charitable Donations, ___ TAX NOTES FEDERAL ___ (2025).
Foreign Gift Reporting Disputes: Exploring Three New Cases and an IRS Policy Shift, __ INTERNATIONAL TAX JOURNAL __ (2025).
What $1 Can Get You: Expanding Standards for “Qualified Offers” in Tax Disputes, ___ ___ TAXES — THE TAX MAGAZINE ___ (2025).
Compiling 10 Obscure Issues as FBAR Battles Mature, __ JOURNAL OF TAXATION ___ (2024); republished in ___ JOURNAL OF INTERNATIONAL TAXATION___ (2024).
Five New Events in 2024 Affecting Employee Retention Credit Disputes, ___ TAX NOTES FEDERAL ___ (2024).
Third Case on Allocation among Designers of Section 179D Deductions for Energy Efficient Commercial Property, ___ JOURNAL OF TAXATION __ (2024).
Altered, Backdated and Inconsistent Documents Not Enough for Fraud, ___ TAX NOTES FEDERAL ___ (2024).
Improper ERC Claims: IRS vs. Taxpayers vs. Payroll Companies, ___ TAX NOTES FEDERAL ___ (2024).
A Look at the Second ERC Voluntary Disclosure Program, 185(4) TAX NOTES FEDERAL 697 (2024).
Surprising New FBAR Cases: A Mixed Bag for Taxpayers Facing Foreign Account Penalties, __ JOURNAL OF TAXATION ___ (2024); republished in ___ JOURNAL OF INTERNATIONAL TAXATION___ (2024).
Evaluating Three Conservation Easement Settlement Offers, 184(6) TAX NOTES FEDERAL 1083 (2024).
How the IRS Can Recapture ERC Refunds and Interest, ___ TAX NOTES FEDERAL ___ (2024).
Erroneous Refund Suits for ERCs and Effects of Novel Case, ___ TAX NOTES FEDERAL ___ (2024).
Exploring Recent Cases and IRS Guidance on Unique International Disclosure Duties for Dual Residents, ___ INTERNATIONAL TAX JOURNAL 40 (2024).
The Latest on Foreign Trusts: Enforcement Actions, Relief Measures, New Cases, Proposed Regulations, and More, ___ INTERNATIONAL TAX JOURNAL ___ (2024).
Expatriation, Form 8854, Invalidation of IRS Notice, and Next Steps, ___ INTERNATIONAL TAX JOURNAL ___ (2024).
Administrative, Legislative and Executive Actions to Address ERC Claims, ___ TAX NOTES FEDERAL ___ (2024).
Private Placement Life Insurance: Potential Tax Changes and Reasons Why, __ JOURNAL OF TAXATION ___ (2024); republished in __ PRACTICAL TAX STRATEGIES __ (2024); republished in ___ESTATE PLANNING __ (2024
A Comprehensive Look at ERC Enforcement Tactics So Far, 183 TAX NOTES FEDERAL 1729 (2024).
Improper ERC Claims: Liability for Third Party Payers, Employers, Both? , ___ TAX NOTES FEDERAL ___ (2024).
CRATs as Listed Transactions? Analyzing IRS Actions and Taxpayer Options, ___ TAX NOTES FEDERAL ___ (2024).
IRS Attempts to Reduce Warnings to Taxpayers about Making Third Party Contacts, ___ TAXES — THE TAX MAGAZINE ___ (2024); republished in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2024).
IRS Wins on Inventory Issue in Three Conservation Easement Cases, 183 (7) TAX NOTES FEDERAL 1213 (2024).
Conservation Easement Settlement Initiatives in 2020 and 2024, ___ TAX NOTES FEDERAL ___ (2024).
New Case Shows Strategic Considerations in “Cooperating” with IRS Audits, ___ TAXES — THE TAX MAGAZINE ___ (2024); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2024).
Employee Retention Credits: How Fraud by Preparers Could Affect Taxpayers, ___ TAX NOTES FEDERAL ___ (2024).
Employee Retention Credits: Probing the Strength of IRS Penalty Threats, ___ TAX NOTES FEDERAL ___ (2024).
More on IRS Strategies to Reopen Closed Assessment Periods, __ JOURNAL OF TAXATION __ (2024); republished in __ JOURNAL OF INTERNATIONAL TAXATION __ (2024).
ERC Claims as Reportable Transactions: Threats, Consequences, and Defenses, ___ TAX NOTES FEDERAL ___ (2024).
ERCs and “Protective” Amended Income Tax Returns, ___ TAX NOTES FEDERAL ___ (2024).
Comparing IRS Settlements: Easements and Employee Retention Credits, ___ TAX NOTES FEDERAL ___ (2024).
ERC Challenges to the IRS, by the IRS, and among Various Parties, ___ TAX NOTES FEDERAL ___ (2024).
ERC Enforcement Tactics: Analyzing the IRS’s Carrots and Sticks So Far, ___ TAX NOTES FEDERAL ___ (2024).
IRS Tries to Further Limit ERC Claims under Governmental Order Test, ___ TAX NOTES FEDERAL ___ (2024).
Tax Court Says “As Such” Means Much: Early IRS Victory in Battle over SECA Taxes and Limited Partners,”__ JOURNAL OF TAXATION __ (2024); republished in ___ PRACTICAL TAX STRATEGIES ___ (2024); republished in ___ TAXATION OF EXEMPTS __ (2024); republished in __ CORPORATE TAXATION ___ (2024).
Aroeste v. United States: Narrow FBAR Dispute Generates Broad Victories for All Taxpayers, ___ TAXES — THE TAX MAGAZINE ___ (2024); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2024).
Valuation Loss in Recent Easement Case Obscures Silver Linings, ___ TAX NOTES FEDERAL ___ (2023).
Foreign Gifts and Foreign Trusts: Taxpayers Still Seeking Court Guidance after Two Government Concessions, 101(12) TAXES — THE TAX MAGAZINE ___ (2023).
IRS Attacks on Art Donations: Old Techniques, New Hurdles, __ TAX NOTES FEDERAL __ (2023).
Comparing Consequences of Obtaining Improper PPP and ERC Benefits: Taxpayers Might Be Surprised, ___ JOURNAL OF TAXATION __ (2023); republished in ___ PRACTICAL TAX STRATEGIES ___ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ CORPORATE TAXATION ___ (2023).
Employee Retention Credits: What the IRS Did Not Do, Did Do, and Might Do, 181(4) TAX NOTES FEDERAL 619 (2023).
Employee Retention Credits: Success Requires Mastery of Procedural and Substantive Rules, __ TAX NOTES FEDERAL __ (2023).
Employee Retention Credits: Exploring Reasons for Prolonged Claims, __ TAX NOTES FEDERAL __ (2023).
Employee Retention Credits: IRS Clarifies Limited Eligibility of Federal Credit Unions, 180(10) TAX NOTES FEDERAL 1615 (2023).
Employee Retention Credits: Issues Arise as Finger-Pointing Begins, __ TAX NOTES FEDERAL __ (2023).
Employee Retention Credits: Government Orders, Suspended Operations, and Supply Chains, 180(9) TAX NOTES FEDERAL 1413 (2023).
Employee Retention Credits: Analyzing Key Issues for “Promoters” and other “Enablers,” __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023).
Employee Retention Credits: Analyzing Key Issues for Taxpayers Facing IRS Audit, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023).
Employee Retention Credits: Analyzing Congressional and IRS Guidance from Start to Finish, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023).
Character Counts: IRS Shifts Focus to Original Landowners in Conservation Easement Disputes 7(180) TAX NOTES FEDERAL 1077 (2023).
California's Settlement Initiative for Conservation Easements, 180(4) TAX NOTES FEDERAL 543 (2023).
IRS Calls Treaty-Based Positions for Malta Pensions Listed Transactions, 111(28) TAX NOTES FEDERAL 169 (2023).
The IRS Challenges Gifts to and from Foreign Persons: Analyzing Two Recent Victories for Taxpayers, ___ INTERNATIONAL TAX JOURNAL 31 (2023); reprinted in ___ TAXES — THE TAX MAGAZINE ___ (2023).
The Unavoidable Overlap of Promoter Investigations and Taxpayer Audits: Interactions and Insights __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Holy CRAT! Exploring Options for Taxpayers after Early Tax Court Losses ___ TAX NOTES FEDERAL __ (2023).
IRS Claims It Can Revive Closed Assessment-Periods in International Tax Disputes, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF INTERNATIONAL TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
IRS Issues Safe Harbors for Easement Deeds: Technical Battles Will Persist, __ TAX NOTES FEDERAL ___ (2023).
Tax Court Rules that IRS Cannot Assess and Collect Form 5471 Penalties: Many Questions Triggered by Novel Ruling, ___ INTERNATIONAL TAX JOURNAL ___ (2023).
Easement Evolution: Proposed Regulations, New Law, and Public Comments, __ TAX NOTES FEDERAL ___ (2023).
Canadian Retirement Plans and Accounts: Evolving Special Rules and Enduring IRS Problems, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF INTERNATIONAL TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
IRS Concedes First Case of Form 3520 Penalties for Unreported Foreign Gifts: A Bittersweet Victory, __ TAX NOTES FEDERAL ___ (2023).
Foreign Trusts, Foreign Gifts and Ongoing Disputes: Public Comments and Possible Changes, ___ INTERNATIONAL TAX JOURNAL ___ (2023).
Does Residency Status under a Treaty Affect FBAR Duties? District Court Order Ponders Potential “Escape Hatch” for Taxpayers, ___ INTERNATIONAL TAX JOURNAL ___ (2023).
Novel Case Shows Social Media Might Jeopardize Tax Relief, 179(1) TAX NOTES FEDERAL 59 (2023).
IRS Still Mining for Foot Faults in Conservation Easement Cases? Tax Court Takes Step in Right Direction, ___ TAX NOTES FEDERAL ____ (2023).
Is the “Ultimate Tax Plan” Nearing Ultimate Rejection by the Tax Court? ___ TAX NOTES FEDERAL ____ (2023).
IRS Introduces New Challenge to Tax-Related Insurance: From Easements to Elsewhere, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Energy Efficient Commercial Building Property and Section 179D: New Tax Court Case Offers Guidance on Allocation of Deductions, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Same Standard, Different Taxes: The IRS and New York Attack Limited Partner Exception, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF CORPORATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
An Oldie But Not a Goodie: Putting a New Conservation Easement Case into Perspective, ___ TRUST & ESTATES JOURNAL __ (2023).
The IRS Takes Another Crack at Demonizing Easement Donations: Proposed Regulations and New Focus on Land Trusts, __ TAXATION OF EXEMPTS ___ (2023); republished in __ REAL ESTATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
Revenue Procedure 2022-39: Collaboration Salvages Special Penalty-Avoidance Rules for Large Entities, ___ TAXES — THE TAX MAGAZINE ___ (2023); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2023).
The Accuser Becomes the Accused in the Conservation Easement Context: Courts Hold that IRS Violated the Law in Green Valley Investors and Elsewhere, __ JOURNAL OF TAXATION ___ (2023); republished in __ REAL ESTATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
So Close, Yet So Far Away, from the Desired Tax Result: Three Recent Cases Showing Pivotal Role of Closing Agreements ___ TAXES — THE TAX MAGAZINE ___ (2023); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2023).
Tax Court Showdown over SECA Taxes and Limited Partners: Exploring the Catalyst for the Second Case of Many, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF CORPORATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
Glade Creek and Champions Retreat: New Cases Bolster Special Conservation Easement Valuation Methods, ____ TAX NOTES FEDERAL ___ (2022).
Harbingers of More IRS Enforcement of Repatriation/Transition Taxes, ____ TAXES — THE TAX MAGAZINE 41 (2022); republished _____ INTERNATIONAL TAX JOURNAL ___ (2022).
Extreme IRS Actions Fortify Taxpayer Disclosure Defenses in Conservation Easement Disputes, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Foreign Gifts, Forms 3520, Big Penalties, and a Pending Case 177(1) TAX NOTES FEDERAL 57 (2022); republished in 108(1) TAX NOTES INTERNATIONAL 45 (2022).
Bait and Switch? Multi-Case Dispute Shows Risks of Participating in Certain IRS Disclosure Programs, _____ INTERNATIONAL TAX JOURNAL ___ (2022).
Recent Court Rulings Confirm Proper Conservation Easement Valuation Method: Highest and Best Use, Before and After Method, and Discounted Cash-Flow Analysis. ___ TAX NOTES FEDERAL ___ (2022).
Tax Incentives, Economic Substance, and Partnership Validity: New Case Undercuts IRS Attacks by IRS, __ JOURNAL OF TAXATION ___ (2022); republished in __ JOURNAL OF ORPORATE TAXATION __ (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in __ TAXATION OF EXEMPTS __ (2022).
Opportunity Zones, Late Elections, and New Enforcement and Oversight Actions, 137(5) JOURNAL OF TAXATION 3 (2022); republished in __ JOURNAL OF CORPORATE TAXATION __ (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in __ TAXATION OF EXEMPTS __ (2022); republished in _ REAL ESTATE TAXATION __ (2022).
New Case Illustrates Permanent Effect of Concessions Made by the IRS or Taxpayers during a Tax Dispute, ___ TAXES — THE TAX MAGAZINE __ (2022).
Involuntary Disclosure by the IRS about Voluntary Disclosure Program for Taxpayers: Analyzing the Fourth Round of Guidance, __ INTERNATIONAL TAX JOURNAL ___ (2022); republished in ___ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2022).
New Tax Court Case Shows that the IRS Is Getting “Sirius” about SECA taxes and the Limited Partner Exception, __ CORPORATE TAXATION __ (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in __ TAXATION OF EXEMPTS __ (2022).
Opportunity Zones, Tax Benefits, Criticisms, and Early IRS Enforcement, 137(4) JOURNAL OF TAXATION 3 (2022); republished in 49(5) CORPORATE TAXATION 3 (2022); republished in 109(5) PRACTICAL TAX STRATEGIES __ (2022); republished in 34(2) TAXATION OF EXEMPTS 6 (2022); republished in _ REAL ESTATE TAXATION __ (2022).
Expedited Challenges to Economic Substance: Exposure for Taxpayers and Problems for the IRS, __ JOURNAL OF TAXATION 3 (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in _ REAL ESTATE TAXATION __ (2022).
The Rise and Fall of Malta Pensions: Taxpayer Positions, IRS Enforcement, and Remaining Solutions, ___ TAX NOTES FEDERAL ___ (2022); republished in ___ TAX NOTES INTERNATIONAL ___ (2022).
Improper Disclosures of Taxpayer Data by the IRS under Section 6103: Recovering Punitive Damages Despite No Actual Damages, _ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022).
Small Employment Tax Case Triggers Big Ruling for All Voluntary Disclosure Programs, (2022).
Valuation, Highest and Best Use, and Conservation Easements: New IRS Attacks of Old Appraisal Methods, ___ TAX NOTES FEDERAL ___ (2022); republished in 2022 TAX NOTES TODAY ____ (2022).
Expatriating Taxpayers and Unfiled Forms 8854: Administration Proposes Disparate Treatment Based on Financial Status, ___ INTERNATIONAL TAX JOURNAL ___ (2022).
Replacing Sticks with Carrots When It Comes to Tax Disclosures? New Proposals regarding Form 8275-R, _ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___ TAXATION OF EXEMPTS ___ (2022).
IRS Announces Newest Version of its Comprehensive Voluntary Disclosure Program: Analyzing the Evolution Over Five Years, ___ INTERNATIONAL TAX JOURNAL ___ (2022).
Recent Refund Case Shows Primacy of Tax Procedure, ___PRACTICAL TAX STRATEGIES __ (2022); republished in ____ TAXATION OF EXEMPTS __ (2022).
New Tax Court Case Explores Boundaries of “Qualified Offers” to the IRS, ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2022); republished in ___ TAXES — THE TAX MAGAZINE ___ (2022).
International Tax Non-Compliance, Exit Taxes, Special Treatment for Accidental Americans, and Urgency Created by Recent Whistleblower Actions, ___ INTERNATIONAL TAX JOURNAL __ (2022).
New Rules in 2022 for Litigating Worker Classification and Section 530 Relief Cases in Tax Court, 24(1) JOURNAL OF TAX PRACTICE & PROCEDURE 51 (2022).
Comparing Federal and State Proposals for Resolving Conservation Easement Disputes, ___TAXATION OF EXEMPTS ___ (2022); republished in _ JOURNAL OF REAL ESTATE TAXATION __ (2022).
Analyzing Obstacles for the IRS in Approaching Partners During Partnership Tax Disputes, _ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___TAXATION OF EXEMPTS ___ (2022); republished in _ JOURNAL OF REAL ESTATE TAXATION __ (2022).
Case Shows Tricky Issues with Making “Deposits” with the IRS to Stop Interest Accrual during Lengthy Tax Disputes, __ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___TAXATION OF EXEMPTS ___ (2022); republished in _ JOURNAL OF REAL ESTATE TAXATION __ (2022).
Series of Tax Court Orders Allowing Nonconsensual Depositions by IRS: Aberration or Trend? ____ TAXES — THE TAX MAGAZINE ___ (2022).
Achtung with Your Stiftung: Evolving Concept of Foreign Trusts and Potential Relief for Taxpayers, __ JOURNAL OF INTERNATIONAL TAXATION ___ (2022); republished in ___ __ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___ESTATE PLANNING ___ (2022).
No Notice, No Examination, No Problem: IRS Further Abolishes Procedural Protections for Appraisers, ___ JOURNAL OF REAL ESTATE TAXATION ___ (2022); republished in ___TAXATION OF EXEMPTS ___ (2022); republished in ___ESTATE PLANNING ___
(2022); republished in ___JOURNAL OF TAXATION ___ (2022).
Reasonable IRS Appraisal Triggers Conservation Easement Settlement, 174(1) TAX NOTES FEDERAL 55 (2022); republished in 2022 TAX NOTES TODAY 13-10 (2022).
Section 179D Deduction for Energy Efficient Commercial Building Property: IRS Attacks Allocations as Part of Compliance Campaign, ___ JOURNAL OF TAXATION __ (2022); republished in __ JOURNAL OF REAL ESTATE TAXATION __ (2022).
IRS Disputes Which “Limited Partners” Escape SECA Taxes Under Section 1402, ___ JOURNAL OF CORPORATE TAXATION ___ (2022).
Heads the IRS Wins, Tails the Taxpayers Lose: Analyzing Inconsistent Positions on the Meaning of “Limited Partners” ___ JOURNAL OF CORPORATE TAXATION ___ (2022).
Analyzing the Long Journey to Chaos: SECA Taxes, Limited Partner Exception, and Effects of Government Inaction, ___ JOURNAL OF CORPORATE TAXATION ___ (2021).
IRS Suffers Second Court Loss for Failing to Properly Warn Taxpayers about Third-Party Contacts during Audits, ___TAXES __(2021); ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2021).
Can Foreign Tax Credits Offset Net Investment Income Taxes? Tax Court Holds that It Depends on the Treaty, ___ JOURNAL OF INTERNATIONAL TAXATION __ (2021); PRACTICAL TAX STRATEGIES __ (2021).
The IRS “Stacks” International Penalties in Foreign Trust Disputes: Two Recent Cases and Earlier IRS Guidance Reveal the Playbook, 99(11) TAXES — THE TAX MAGAZINE ___ (2021).
International Tax Disputes: Recent Cases Show Ways Taxpayers Give the IRS Forever to Audit, Tax and Penalize, 47(6) INTERNATIONAL TAX JOURNAL __ (2021).
Are the IRS’s Positions “Substantially Justified?” New Cases Clarify Standards for Reimbursements to Taxpayers under Section 7430, ___ PRACTICAL TAX STRATEGIES __ (2021); republished in ___ JOURNAL OF TAXATION __ (2021).
Recent Tax Court Case Reveals Rare Use of Form 5471 Penalty Defenses, 47(5) INTERNATIONAL TAX JOURNAL __ (2021).
Neither Death Nor Distance Erases the Issues: IRS Actions against Deceased or Absconding Taxpayers, ___ JOURNAL OF INTERNATIONAL TAXATION __ (2021); republished in __ ESTATE PLANNING __ (2021).
Here Comes the Tax Enforcement, There Go the Passports: Analyzing the Evolution of Section 7345 during Its First Five Years, ___ TAXES — THE TAX MAGAZINE ___ (2021).
30 Wrongs Do Not Make A Right: Revealing Extraordinary IRS Actions in Conservation Easements Disputes, ___ TAXATION OF EXEMPTS ___ (2021); republished in ___ JOURNAL OF TAXATION ___ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021).
Recent Case Highlights Converge of Substance and Procedure in International Tax Disputes, ___ JOURNAL OF INTERNATIONAL TAXATION ___ (2021); republished in ___ JOURNAL OF TAXATION ___ (2021).
It’s Not Over Till It’s Over: Lessons from Crandall about Closing Agreements and Key Procedural Issues in Tax Disputes, ____ INTERNATIONAL TAX JOURNAL __ (2021).
Disputing FBAR Penalties: Mendu Case Clarifies How Much Taxpayers Must Pay to Play, ____ INTERNATIONAL TAX JOURNAL __ (2021).
Can the IRS Really Do That? Third Party Contacts, Notification Duties, Reprisal Exception, and More, ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2021).
Three New IRS Challenges to Tax Result Insurance in Conservation Easement Disputes, __ JOURNAL OF TAXATION __ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021); republished __TAXATION OF EXEMPTS ___ (2021).
Harsh Consequences of Late Forms 1120-F, New Tax Court Case, and Solutions Still Available to Foreign Corporations, __ INTERNATIONAL TAX JOURNAL __ (2021); republished in ___ TAXES — THE TAX MAGAZINE __ (2021).
Court Overturns Legendary FBAR Case, Bedrosian, But Government Settlement Elsewhere Encourages Taxpayers with Foreign Account Issues, ___ INTERNATIONAL TAX JOURNAL __ (2021).
20 Recent IRS Enforcement Actions in Conservation Easement Disputes: Awareness and Preparation Are Key, __ JOURNAL OF TAXATION __ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021); republished __TAXATION OF EXEMPTS ___ (2021).
Partnerships, Making “Qualified Offers,” and Conservation Easement Disputes: Analyzing Problems with the IRS’s Positions, Now and Later, ___ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2020); republished in ___ TAXES — THE TAX MAGAZINE __ (2021).
Conservation Easements and Pine Mountain: Favorable Rulings by Court of Appeals and Pending Issues JOURNAL OF TAXATION __ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021); republished __TAXATION OF EXEMPTS ___ (2021).
Conservation Easement Settlement Initiative: More IRS Guidance, More Uncertainty, ___ TAX NOTES FEDERAL ____ (2020).
Newest IRS Action in Conservation Easement Disputes: Same Data Used
Against Different Parties, ____ JOURNAL OF TAXATION ____ (2020).
Depriving Partnerships of Access to the Independent Office of Appeals: Old and New IRS Tactics in Challenging Conservation Easements; ____ JOURNAL OF TAX PRACTICE & PROCEDURE ____ (2020); republished in ____ TAXES - THE TAX MAGAZINE ____ (2021).
Questions Remain about Conservation Easement Settlement Initiative, 168(12) TAX NOTES FEDERAL 2219 (2020); republished in 97(12) TAX NOTES STATE 1265 (2020).
Taxpayers Die but Their International Penalties Live On: Recent Cases Addressing the Broad Scope of Post-Death Assessment and Collection, __ JOURNAL OF INTERNATIONAL TAXATION ___ (2020); republished in __ JOURNAL OF TAXATION ___ (2020).
Lessons from an International Tax Dispute: Three Interrelated Cases, in Three Different Proceedings, Generating Three Separate Liabilities, ____ INTERNATIONAL TAX JOURNAL ____ (2020).
Conservation Easement Battles: The IRS Attempts to Use "Syndication Expenses" and Forms 8283 to Disallow Charitable Deductions, ____ JOURNAL OF TAX PRACTICE & PROCEDURE ____ (2020); republished in ____ TAXES - THE TAX MAGAZINE ____ (2020).
IRS Issues New Form 14457 and Instructions regarding Its Comprehensive Domestic and International Voluntary Disclosure Program: Analyzing Key Aspects, ____ INTERNATIONAL TAX JOURNAL ____ (2020).
IRS Challenges “Commercial Forestry” in Conservation Easement Disputes: Getting to the Root of the Matter, ____TAXES - THE TAX MAGAZINE ____ (2020).
Conservation Easement Disputes, Expansive Data Demands by the IRS, and Scope of the Tax Practitioner Privilege under Section 7525, ____ PRACTICAL TAX STRATEGIES ____ (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2021).
Civil Suit Emphasizes Critical Role of Notifications by Tax Matter Partners in Conservation Easement and Other Tax Disputes, JOURNAL OF TAX PRACTICE & PROCEDURE (2020).
New IRS Enforcement Campaign to Stop Tax Violations by Nonresident Aliens Renting and Selling U.S. Real Property, ____ JOURNAL OF TAXATION ____ (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2020).
Second Court Rejects ""Constructive Knowledge" Theory for Willful FBAR Penalties," ____ INTERNATIONAL TAX JOURNAL ____ (2020).
Five Obscure IRS Actions in 2020 with Serious Implications for Conservation Easement Disputes, ____ JOURNAL OF TAXATION ____ (2020); republished in ____ TAXATION OF EXEMPTS (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2020).
Conservation Easement Enforcement: IRS Quietly Eliminates Procedural Protections for Appraisers, 132(5) JOURNAL OF TAXATION 17 (2020); republished in 31(6) TAXATION OF EXEMPTS 13 (2020); and ____ JOURNAL OF REAL ESTATE TAXATION ____ (2020).
Foreign Retirement and Savings Plans, Waiver of Forms 3520 and Forms 3520-A, and Limits of Rev. Proc. 2020-17, ____ INTERNATIONAL TAX JOURNAL ____ (2020); republished in ____ TAXES - THE TAX MAGAZINE ____ (2020).
Conservation Easements, Partners, and Qualified Amended Returns? 166(3) TAX NOTES FEDERAL 373 (2020).
Recent Foreign Trust Case Establishes Penalty Limits for Form 3520 and Form 3520-A Violations, ____ INTERNATIONAL TAX JOURNAL ____ (2020); republished in ____ JOURNAL OF TAX PRACTICE & PROCEDURE ____ (2020).
Evolution of Special Rules for Claiming Disaster Losses: Analyzing Remedies for Taxpayers Who Miss Election Deadlines, 104(2) PRACTICAL TAX STRATEGIES ____ (2020).
Conservation Easements, Legitimate Risks, and Potential Issues Related to Tax Result Insurance: Identifying Realities Facing the IRS, ____ PRACTICAL TAX STRATEGIES ____ (2019); republished in 31(4) TAXATION OF EXEMPTS ____ (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2019).
Conservation Easements, Partnerships, Risks, and Profitability: U.S. Government Takes Contradictory Positions in Tax and Securities Cases, ___ JOURNAL OF TAXATION OF FINANCIAL PRODUCTS ___ (2019).
Clarifying the Reasonable-Reliance Defense to Penalties in an E-Filing Era: An Analysis of Boyle, Haynes, Intress, and More, ___ JOURNAL OF TAXATION ___ (2020); republished in __ PRACTICE TAX STRATEGIES ___ (2020).
IRS Introduces Relief Procedures for Former U.S. Citizens: Path to Avoid the Exit Tax, Income Taxes, and Penalties Despite Past Non-Compliance, INTERNATIONAL TAX JOURNAL ___ (2019); republished in ___ TAXES — THE TAX MAGAZINE __ (2020).
Conservation Easements, Recent Mayo Clinic Case, and Expanded Defenses to IRS Attacks on “Conservation Purpose,” ___ JOURNAL OF REAL ESTATE TAXATION __ (2019); republished in ___ JOURNAL OF TAXATION ___ (2019).
Clarifying Misconceptions about Extending Assessment Periods and “Cooperating” during IRS Audits, __ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2019); republished in ___ TAXES — THE TAX MAGAZINE __ (2020).
More FBAR Penalty Losses and Lessons: The Significance of Rum and Ott, ___ INTERNATIONAL TAX JOURNAL ___ (2019).
Fee Simple Charitable Donations Instead of Conservation Easements: Case on Mining Property Undercuts IRS's Core Positions, ___ PRACTICE TAX STRATEGIES ___ (2019); republished in ___ TAXATION OF EXEMPTS ___ (2019).
Conservation Easements, "Substantially Similar" Transactions, and the Reach of Notice 2017-10, ___ JOURNAL OF REAL ESTATE TAXATION ___ (2019); republished in ___ JOURNAL OF TAXATION 23 (2019).
Flume, Boyd, and Cohen: Three Recent FBAR Cases Yielding Important New Lessons, 45(4) INTERNATIONAL TAX JOURNAL 31 (2019).
Making "Qualified Offers" in Partnership Disputes: Extreme Positions by the IRS in Conservation Easements Cases Might Backfire, ___ JOURNAL OF PASSTHROUGH ENTITIES __ (2019).
IRS Amnesty Covers More than Foreign Accounts: Analyzing the Updated Voluntary Disclosure Practice, New International Tax Withholding Procedure, and Guidelines for Late Returns by Foreign Corporations, 97(6) TAXES — THE TAX MAGAZINE 19 (2019); republished in 45(3) INTERNATIONAL TAX JOURNAL __ (2019).
Conservation Easements, Partnerships, Risks and Profitability: U.S. Government Takes Contradictory Positions in Tax and Securities Cases, 16(3) JOURNAL OF TAXATION OF FINANCIAL PRODUCTS _____(2019).
What Garrity Teaches about FBARs, Foreign Trusts, "Stacking" of International Penalties, and Simultaneously Fighting the U.S. Government on Multiple Fronts, 20(6) JOURNAL OF TAX PRACTICE AND PROCEDURE 27 (2019).
Champions Retreat: Conservation Easements, Clarifications on "Significant" Preservation, and Lessons from Issues Unaddressed by the Tax Court, ______ JOURNAL OF REAL ESTATE TAXATION _____(2019); republished in 131(1) JOURNAL OF TAXATION 23 (2019).
United States v. Horowitz: Sixth Case Analyzing Constructive Knowledge as Determinant of FBAR Penalties, 45(2) INTERNATIONAL TAX JOURNAL 23 (2019); republished in _____TAXES ---THE TAX MAGAZINE___(2019).
Pine Mountain Preserve and Conservation Easements: Victory in Disguise for Taxpayers? ______ JOURNAL OF REAL ESTATE TAXATION ____(2019); republished in 130(5) JOURNAL OF TAXATION 22 (2019).
Conservation Easements, Notice 2017-10, Injunction Action, and the Potential Reach of Return Preparer Penalties under Section 6694, 21(1) JOURNAL OF TAX PRACTICE & PROCEDURE 23 (2019).
Constructive Knowledge and FBAR Penalties: Does Merely Filing a Form 1040 Suffice to Establish “Willfulness?” 45(1) INTERNATIONAL TAX JOURNAL 35 (2019); republished in 97(5) TAXES — THE TAX MAGAZINE __ (2019).
Appellate Court Jeopardizes First Holding of Non-Willfulness in FBAR Penalty Case: Round Three of the Bedrosian Battle , 30(5) JOURNAL OF INTERNATIONAL TAXATION 37 (2019); republished in 130(4) JOURNAL OF TAXATION 20 (2019).
Courts Hold that U.S. Government Can Pursue Executors, Representatives, Fiduciaries, Beneficiaries, Distributees, and Others for FBAR Penalties Assessed Against Deceased Taxpayers, 30(3) JOURNAL OF INTERNATIONAL TAXATION ___ (2019); republished in 130(3) JOURNAL OF TAXATION 16 (2019).
Extended Delays by IRS in Processing International Voluntary Disclosure Cases : Expatriations Thwarted, Estate Taxes Imposed, and Solutions Explored, 44(6) INTERNATIONAL TAX JOURNAL 13 (2019); republished in _____ TAXES - THE TAX MAGAZINE _______ ( 2019).
Anatomy of a Worker-Classification Dispute with the IRS: Securing Section 530 Relief, Avoiding Employee Status, Shifting the Burden of Proof, Recouping Fees, and More, ___PRACTICAL TAX STRATEGIES _____(2019).
Court Bucks the Trend in Willful FBAR Penalty Cases: Merely Signing Tax Returns Does Not Establish Willfulness, 44(6) INTERNATIONAL TAX JOURNAL _____ (2018); republished in 97(1) TAXES - THE TAX MAGAZINE 23 ( 2019)
What Constitutes a "Willful" FBAR Violation? Comprehensive Guidance Based on Eight Important Cases, 129(5) JOURNAL OF TAXATION 24 (2018); republished in 29(11)JOURNAL OF INTERNATIONAL TAXATION 33 (2018).
Alarming U.S. Tax Rules and Information - Reporting Duties for Foreign Retirement Plans and Accounts: Analyzing Problems and Solutions, 129(4) JOURNAL OF TAXATION 14 (2018); republished in 29 (10) JOURNAL OF INTERNATIONAL TAXATION 27 (2018).
Court Holds that Pervasive Ignorance Is No Defense to Willful FBAR Penalties: This and Other Lessons from United States v. Garrity, 44(4) INTERNATIONAL TAX JOURNAL 51 (2018).
More IRS Guidance about Section 7345, Seriously Delinquent Tax Debts, and Passport Revocation: A Comprehensive Analysis, 20(2)JOURNAL OF TAX PRACTICE & PROCEDURE 17 (2018).
New Procedures for Late Forms 1120-F and Late-Filing Waivers: The Evolution of IRS Standards and Open Issues for Foreign Corporations, 44(3) INTERNATIONAL TAX JOURNAL 19 (2018).
Extended Assessment Periods and International Tax Enforcement: Rafizadeh v. Commissioner, Unreported Foreign Assets, and Use of FATCA Weapons , 96(6) TAXES — THE TAX MAGAZINE 35 (2018).
IRS Starts Depriving Tax Debtors of Passports in 2018: New Guidance about Section 7345 and Future Tax Court Disputes, 20(1) JOURNAL OF TAX PRACTICE & PROCEDURE 37 (2018).
The Importance of Lingering TEFRA Partnership Procedures: Exploring Who Can File Court Petitions and the Consequences for Mistakes, 19(6) JOURNAL OF TAX PRACTICE & PROCEDURE 25 (2018).
Willful FBAR Penalty Case Shows Importance of Protecting Privileged Communications: What Kelley-Hunter Adds to the Foreign Account Defense Discussion, 44(1) INTERNATIONAL TAX JOURNAL 15 (2018).
Analysis of the Reasonable Cause Defense in Non-Willful FBAR Penalty Case: Teachings from Jarnagin, 128(4) JOURNAL OF TAXATION 6 (2018); republished in JOURNAL OF INTERNATIONAL TAXATION (2018).
First Taxpayer Victory in a Willful FBAR Penalty Case: Analyzing the Significance of Bedrosian for Future Foreign Account Disputes (Part 2),” 128(3) JOURNAL OF TAXATION 14 (2018); republished in 29(3) JOURNAL OF INTERNATIONAL TAXATION __ (2018).
First Taxpayer Victory in a Willful FBAR Penalty Case: Analyzing the Significance of Bedrosian for Future Foreign Account Disputes (Part 1),” 128(2) JOURNAL OF TAXATION 12 (2018); republished in 29(3) JOURNAL OF INTERNATIONAL TAXATION 54 (2018).
IRS Sets Its Sights on Nonresident Aliens with U.S. Rental Property: New Study, Significant Violations, Compliance Initiative, and Remaining Options, 45(2) JOURNAL OF REAL ESTATE TAXATION 14 (2018).
Assessing Tax Liabilities is One Thing, Collecting Them Abroad is Another: New Case Shows International Reach of the IRS, 127(5) JOURNAL OF TAXATION 2015 (2017); republished in 34 JOURNAL OF INTERNATIONAL TAXATION 29(2) (2017).
The Importance of Lingering TEFRA Partnership Procedures: Exploring Who Can File Court Petitions and the Consequences for Mistakes, ___ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2018).
Willful FBAR Penalty Case Shows Importance of Protecting Privileged Communications: What Kelley-Hunter Adds to the Foreign Account Defense Discussion, __ INTERNATIONAL TAX JOURNAL ___ (2018).
Court Applies Reasonable Cause Defense to FBAR Setting: Early Teachings from Jarnagin, ___ JOURNAL OF TAXATION ___ (2018); republished in ____ JOURNAL OF INTERNATIONAL TAXATION __ (2018).
First Taxpayer Victory in a Willful FBAR Penalty Case: Analyzing the Significance of Bedrosian for Future Foreign Account Disputes, ___ JOURNAL OF TAXATION ___ (2018); selected for republication in ____ JOURNAL OF INTERNATIONAL TAXATION __ (2018).
Assessing Tax Liabilities is One Thing, Collecting Them Abroad is Another: New Case Shows International Reach of the IRS, 127(5) JOURNAL OF TAXATION 2015 (2017); selected for republication in ____ JOURNAL OF INTERNATIONAL TAXATION __ (2017).
Has the IRS Declared Dead the Substantial Compliance Defense for International Information Returns? Lessons from a New International Practice Unit, ___ INTERNATIONAL TAX JOURNAL ____ (2017).
Can Recent “Willful” FBAR Penalty Cases against Taxpayers Help Tax Firms Fend Off Malpractice Actions? 43(4) INTERNATIONAL TAX JOURNAL 33 (2017).
Section 911 Exclusion: Unique Election, New Case, Lessons Learned, 99(2) PRACTICAL TAX STRATEGIES 4 (2017).
Pre-Trial Win in Worker-Classification Dispute Thanks to Section 530 Does Not Trigger Automatic Fee Recovery under Section 7430, 19(2) JOURNAL OF TAX PRACTICE & PROCEDURE 21 (2017).
Flume v. Commissioner and Form 5471 Penalties for Unreported Foreign Corporations: A Glimpse at Unique Aspects of International Tax Disputes, 95(8) TAXES — THE TAX MAGAZINE 39 (2017).
IRS Deprives Tax Debtors of U.S. Passports under New Section 7345: Open Issues as Enforcement Begins in 2017, 19(1) JOURNAL OF TAX PRACTICE & PROCEDURE 27 (2017).
Unlimited Assessment-Period for Form 8938 Violations: Ruling Shows IRS’s Intent to Attack Multiple Tax Returns, 95(4) TAXES — THE TAX MAGAZINE 31 (2017).
IRS Finalizes Form 5472 Regulations for Foreign-Owned, Domestic, Disregarded Entities, 43(1) INTERNATIONAL TAX JOURNAL 13 (2017).
Government Wins Fourth Straight FBAR Penalty Case: Analyzing Bohanec and the Evolution of “Willfulness,” 126(3) JOURNAL OF TAXATION 110(2017); selected for republication in 28(8) JOURNAL OF INTERNATIONAL TAXATION 34 (2017).
Where Does the Buck Stop? Recent Case Condones Non-Filing of Forms 1065 and Schedules K-1, 18(5) JOURNAL OF TAX PRACTICE & PROCEDURE 27 (2016).
IRS Proposes Form 5472 Filing Duty for Foreign-Owned Disregarded Entities, 42(4)INTERNATIONAL TAX JOURNAL 17 (2016).
Formal Document Requests under Section 982: New Case Expands Definition of “Foreign-Based Documentation” 94(9)TAXES — THE TAX MAGAZINE 33 (2016).
Taxpayer Delivers One-Two Punch to IRS in Recent Worker-Classification Dispute: Victory under Section 530 and Fee Recoupment , 18(3)JOURNAL OF TAX PRACTICE & PROCEDURE 33(2016).
Specified Domestic Entities Must Now File Form 8938: Section 6038D, New Regulations in 2016, and Expanded Foreign Financial Asset Reporting, 42(3) INTERNATIONAL TAX JOURNAL 5 (2016).
Accidental Americans: Unanticipated U.S. Income Taxes, Ongoing Information-Reporting Duties, and Exposure to Expatriation Tax for Green Card Holders, 124(4) JOURNAL OF TAXATION 170 (2016).
Children with Foreign Accounts: Unexpected Income, Schedule B, Form 8938, and FBAR Issues, 124(3) JOURNAL OF INTERNATIONAL TAXATION 134 (2016); selected for republication in 124(3) JOURNAL OF TAXATION 134 (2016).
Form 5471: How Does New IRS Guidance Impact the “Substantially Complete” Defense? 94(4) TAXES — THE TAX MAGAZINE 39 (2016). selected for republication in 42(2) JOURNAL OF INTERNATIONAL TAXATION 33 (2016).
Canadian Retirement Plans: What Does Revenue Procedure 2014-55 Mean for U.S. Tax Deferral, Form 8891, Form 8938, and the FBAR? 41(6) INTERNATIONAL TAX JOURNAL 25-37 (2016).
Form 5472 for Certain Foreign and Domestic Corporations: New Filing Procedures, New Automated Penalties, New Abatement Standards, and More. 93(5)TAXES — THE TAX MAGAZINE 45-60 (2015).
Form 8938 and Foreign Financial Assets: A Comprehensive Analysis of the Reporting Rules after IRS Issues Final Regulations, 41(2) International Tax Journal 25-50 (2015).
Government Wins Second Willful FBAR Penalty Case: Analyzing What McBride Really Means to Taxpayers With Unreported Foreign Accounts, 118(4) Journal of Taxation 187(2013).
IRS Introduces Two Unique Tax-Compliance Remedies for U.S. Persons with Unreported Canadian Retirement Plans and Accounts, 39(1) International Tax Journal 11-20 (2013).
Must Taxpayers File “Timely” Forms 1099 to Obtain Section 530 Relief? Unexpected Answers from a Recent Worker-Classification Case, 91(4) Taxes– The Tax Magazine 55-68 (2013).
Third Time's the Charm: Government Finally Collects "Willful" FBAR Penalty in Williams Case, 117(6) Journal of Taxation 319 (2012).
The New Duty to Report Foreign Financial Assets on Form 8938: Demystifying the Complex Rules and Severe Consequences of Noncompliance, 38(3)International Tax Journal 11 (2012).
Direct Sellers Hit by IRS Worker-Classification Audits: An Analysis of the Obscure Rules, Precedent, and Strategies Applicable to These Workers, 90(8) TAXES – The Tax Magazine 45 (2012).
Limited Liability Company Members and the Passive Activity Loss Rules: IRS Issues Proposed Regulations After Multiple Court Setbacks, 15(1) Journal of Passthrough Entities 51 (2012).
Qualified Amended Returns: Case of First Impression Examines Parameters of this Powerful Taxpayer Remedy, 116(2) Journal of Taxation 96 (2012).
IRS Introduces New Settlement Program for Worker-Classification Issues: Putting the Latest Employment Tax Offer into Perspective, 90(2) TAXES – The Tax Magazine 53 (2012).
Always Say Never: Tax Court Rejects IRS's Extreme Litigation Position in Penalty Cases, 13(5) Journal of Tax Practice & Procedure 43 (2011).
Better Late Than Never: The IRS Radically Changes Aggregation Election Procedures in Passive Activity Cases, 13(5) Journal of Tax Practice & Procedure 25 (2011).
If You're On Call, You're Out of Luck: Tax Court Limits Hours Counted in Passive Activity Loss Disputes, 86(4) Practical Tax Strategies 153 (2011).
The Internal Revenue Service Giveth and the Department of Justice Taketh Away: Recent Court Opinion Jeopardizes Retroactive Administrative FBAR Relief, 114(1) Journal of Taxation 18 (2011).
IRS Granted Major Mulligan in TEFRA Partnership Case: Three Novel Rulings Enable IRS to Avoid One-FPAA-Only Restriction, 89(1) TAXES – The Tax Magazine 47-58 (2011).
District Court Rules That Where There's No Will, There's a Way to Avoid FBAR Penalties, 113(5) Journal of Taxation 293-300 (2010).
Home Sweet "Property"? Tax Court Issues Examines Gain Exclusion on Sale of Principal Residence, 113(3) Journal of Taxation 175 (2010).
When Are Hard Times Hard Enough (for the IRS)? Examining Financial Distress as Reasonable Cause for Penalty Abatement During an Economic Downturn. 88(10) TAXES – The Tax Magazine 37 (2010); selected for republication in 12(5) Journal of Tax Practice & Procedure 29 (2010).
No Returns, No Problem: Tax Court Rules in Case of First Impression that IRS Must Consider "Economic Hardship" in Pre-Levy CDP Cases. 12(1) Journal of Tax Practice & Procedure 27 (2010).
As the World Turns: Court Rebuffs Novel Spin on International Tax Filing Rules, 36(2) International Tax Journal 45-48 (2010).
Strike Three for the IRS in Passive Activity Loss Cases: Courts United in Rejecting Outdated Limited Partnership Theories, 12(5) Journal of Passthrough Entities 59-69 (2009).
Exploring the Limits of State Law in Resolving Federal Tax Disputes: Tax Court Denies the IRS's "Back Door" Approach in Alimony Case, 87(8) TAXES – The Tax Magazine 67-73 (2009).
Two More Blows to Foreign Account Holders: Tax Court Lacks FBAR Jurisdiction and Bankruptcy Offers No Relief from FBAR Penalties, 11(1) Journal of Tax Practice & Procedure 27-34 (2009).
How Much Must One Pay to Play? Recent Case Clarifies Jurisdictional Deposit Requirement in TEFRA Litigation, 11(5) Journal of Passthrough Entities 39-46 (2008).
It's in the Mail, Right? Recent Decision Emphasizes Limitations on the Mailbox Rule, The Practical Tax Lawyer 15-18 (Summer 2008).
Make a Decision Already! Recent Case Highlights How IRS Inaction Can Stymie Taxpayers Requesting Abatement, The Tax Adviser 256-258 (April 2008).
From the Cradle to the Grave: What Remains of Interest Suspension under Section 6404(g)? 10(1) Journal of Tax Practice & Procedure 41-50 (2008); selected for republication in 58(10) The Monthly Digest of Tax Articles 51-63 (2008).
There Are Some "Guaranties" in Life, But Do You Want to Be the One Making Them? Analyzing the Unique Tax Rules for Bad Debt Losses, 10(5) Corporate Business Taxation 29-34 ( 2009).
When Bygones Aren't Bygones: Exploring Solutions for U.S. Persons with Undeclared Canadian Retirement Plans and Accounts, 34(4) International Tax Journal 35-43 (2008).
Beware of the Two-Hatted Tax Matters Partner: Analyzing How Dual Roles Can Impact TEFRA Litigation, 10(6) Journal of Passthrough Entities 31-40 (2007).
Where There's a Will, There's a Delay: Do Recent Legislative Changes to the CDP Rules Solve the Perceived Problems? 85(11) TAXES – The Tax Magazine 39-44 (2007); selected for republication in 9(5) Journal of Tax Practice & Procedure 41-46 (2007).
Seeking Cost Reimbursement in Cases of First Impression: Zealous Advocacy or Pushing Your Luck? 21(3) The Practical Tax Lawyer 15-22 (2007).
Applying Old Theories in New Contexts: Interest Suspension Upheld Where Government Failed to Prove Fraud, 9(3) Journal of Tax Practice & Procedure 15-18, 47-48 (2007).
The Document Locator Number: Little-Known IRS Notation May Establish Tax Return Filing Date, 78(1) Practical Tax Strategies 4-11 (2007).
New Penalties for Undisclosed Foreign Accounts: Putting the Cart before the Horse? 8(3) Journal of Tax Practice & Procedure 29-36 (2006).
Evolution of the FBAR: Where We Were, Where We Are, and Why It Matters. 7(1) University of Houston Business & Tax Law Journal 1-41 (2006); selected for republication in 57(12) The Monthly Digest of Tax Articles 21-41 (2007).
Repatriating Subpart F Income: A Fresh Look at Electing to be Taxed as a Corporation, 38(2) Tax Notes International 173-178 (2005), 2005 Worldwide Tax Daily 70-21 (2005).
The Evolving Treatment of Qualified Foreign Dividends: Where Do We Stand Now? 16 Journal of International Taxation 28 (2005).
You Can Catch More Flies with Honey: Debunking the Theory in the Context of International Tax Enforcement, 83(2) TAXES – The Tax Magazine 29 (2005).
Only Time Will Tell: The Growing Importance of the Statute of Limitations in an Era of Sophisticated International Tax Structuring, 30(2) Brooklyn Journal of International Law 453-484 (2005); selected for republication in 57(6) The Monthly Digest of Tax Articles 1-15 (2007).
Tax Treatment of Foreign Dividends Under the JGTRRA: Further Ambiguities and Opportunities, 15(10) Journal of International Taxation 20-27 (2004).
Regulating Foreign Disregarded Entities with Proposed Form 8858: Try, Try Again, 33(7) Tax Management International Journal 412-425 (2004).
The Impact of Recent Events on Section 911: Rocking the Boat or Capsizing the Vessel? 34 Tax Notes International 285 (2004), 2004 Worldwide Tax Daily 75-12 (2004).
The Foreign Earned Income Exclusion: U.S. International Tax Policy, Political Reality, and the Need to Understand How the Two Intertwine, 37(3) Vanderbilt Journal of Transnational Law 727 (2004).
Florida Forecast: More Rain on the Offshore Parade, 15(3) Lawyer 36-37 (2004).
Reduced Tax Rates on Foreign Dividends Under the Jobs and Growth Relief Reconciliation Act: Ambiguities and Opportunities, 15(7) Journal of International Taxation 14-27 (2004).
The New Federal-State Tax Enforcement Alliance: Carrots, Sticks and Implications for Taxpayers, 13(10) Journal of Multistate Taxation and Incentives 14-23, 46 (2004).
Fight or Flight of U.S.-Based Multinational Businesses: Analyzing the Causes for, Effects of, and Solutions to the Corporate Inversion Trend, 23(3) Northwestern University Journal of International Law and Business 551-588 (2003).
Rethinking Tax-Based Export Incentives: Converting Repeated Defeats Before the WTO Into Positive Tax Policy, 39(1) University of Texas International Law Journal 111-142 (2003).
The Andean Trade Preference Act: Past Accomplishments and Present Circumstances Warrant Its Immediate Renewal and Expansion, 34(4) George Washington University International Law Review 743-788 (2003).
Privilege, Work-Product Doctrine, and Other Discovery Defenses in IRS's International Tax Enforcement, 32(4) Tax Notes International 377-396 (2003), 2003 Worldwide Tax Daily 207-14 (2003).
Reduced Tax on Foreign Dividends: A Dose of Holiday Cheer for U.S. Investors, 14(4) Lawyer 34 (2003).
Revamping the Export-Import Bank in 2002: The Impact of this Interim Solution on the United States and Latin America, 6(1) New York University Journal of Legislation and Public Policy 89-130 (2002).
The NAFTA Trucking Dispute: Pretexts for Noncompliance and Policy Justifications for U.S. Facilitation of Cross-Border Services, 11 University of Minnesota Journal of Global Trade 235-275 (2002).
Partial Revocation of the Caribbean Basin Trade Partnership Act: An Analysis of Hemispheric Injuries and Domestic Benefits, 28 University of North Carolina Journal of International Law and Commercial Regulation 101-143 (2002).
Salvaging Trade, Economic and Political Relations with Mexico in the Aftermath of the Terrorist Attacks: A Call for a Reevaluation of U.S. Policy, 20(1) Boston University International Law Journal 33-72 (2002).
Reauthorizing the Export-Import Bank Affects Trade in the Americas, 9(8) Inter-American Trade Report (2002).
The Continued Dumping and Subsidy Offset Act (Byrd Amendment): A Defeat Before the WTO May Constitute an Overall Victory for U.S. Trade, 10 Tulane University Journal of International and Comparative Law 121-155 (2002).
Trade Promotion Authority: Current Status and Potential Effects on U.S.-Latin America Trade, 9(4) Inter-American Trade Report 1-11 (2002).
U.S. Action to Freeze Assets of Terrorism: Manifest and Latent Implications for Latin America, 17(3) American University International Law Review 625-639 (2001).
The International Monetary Stability Act: Recognizing the Ripeness of this Economic Legislation to Render Benefits for the United States and Mexico, 32(3) University of Miami Inter-American Law Review 375-435 (2001).
Cross-Border Financing: The Impact of Recent Legislation on NAFTA Signatories, 15(2) Texas Transnational Law Quarterly 6-13 (2001).
Overcoming Apathetic Internationalism to Generate Hemispheric Benefits: An Analysis of and Arguments for Recent Secured Transactions Law in Mexico, 10(2) Florida State University Journal of Transnational Law & Policy 133-181 (2001).
U.S. Export Control Changes Concerning Cuba – Potential Gains for U.S. Agriculture, 8(15) Inter-American Trade Report 2139-2147 (2001).
Introduction of U.S. Currency in Ecuador: Arguments for External Participation, 16(2) Florida International Law Quarterly 12-18 (2001).
The New Mexican Insolvency Law: Imperative Judicial Modernization and Policy Justifications for U.S. Assistance, 6(1) UCLA Journal of International Law and Foreign Affairs 45-87 (2001).
Pensions in Brazil: Time for the Harvest, 3(1) Latin Insurance, 22-24 (2001).
Dollarization of Ecuador: Sound Policy Dictates U.S. Assistance to This Economic Guinea Pig of Latin America, 11(1) Indiana University International and Comparative Law Review 79-114 (2000).
Reinsurance in Brazil: The Rough Road to Privatization, 7(2) Journal of Reinsurance 1-12 (2000).
Transformation of the Costa Rican Insurance Market: Losing the Battle, Winning the War, 9(4) Global Reinsurance, 50-52 (2000).
Healthcare in Brazil: Bring Your Own Aspirin, 48(3) Health Insurance Underwriter 35-40 (2000).
Legalities vs. Realities: Privatization of the Nicaraguan Telecommunications Industry Gives New Meaning to the Phrase Caveat Emptor, 15(1) Texas Transnational Law Quarterly 7-11 (2000).
One Step Closer to Privatization? Legal Horizons (2000).
La internacionalidad de los mercados, la responsabilidad objetiva y la comercialización de productos defectuosos provenientes de Chile, 206 Universidad de Concepción (Chile) Revista de Derecho 43-73 (1999).
MERCOSUR and the Insurance Sector: At the Integration Crossroads, 2(3) Latin Insurance 24-27 (1999).
Native Forest Protection in Chile: The Inadequacies of the Recent Environmental Framework Law, 14(1) University of Oregon Journal of Environmental Law and Litigation 225-299 (1999).
El trabajo infantil en América Latina y Perú: un programa para su reducción, 29 Debate Agrario (Peru): Análisis y Alternativos 81-112 (1999).
Certificación forestal: una opción medioambiental de vanguardia para Chile, XV(4) Ambiente y Desarrollo 54-57 (1999).
Pension Reforms in Latin America, Legal Horizons 22-24 (1999).
Timber Certification: An Alternative to the Destruction of the Chilean Forests, 14(2) University of Oregon Journal of Environmental Law and Litigation 301-350 (1999).
The Lome Convention in the Next Millennium: Modification of the Trade/Aid Package, 7(3) University of Kansas Journal of Law & Public Policy 83-104 (1998).

Academic Awards

Harry S. Truman Foundation Scholar
Janice Dawson Quinn Tax Scholar
Tinker Foundation Scholar
Senator James B. Pearson International Fellow
Kansas Journal of Law & Public Policy, member and note contributor
Florida Tax Review, graduate editor

Professional Recognitions

American College of Tax Counsel, Fellow (2019 through 2021)
Chambers USA - Tax Litigation Leader (2009 through 2021)
Georgia Super Lawyers - Tax (2012 through 2022)
Best Lawyers in America - Tax Litigation and Controversy (2019 through 2022)
Legal 500 – Tax Litigation and Controversy (2015 through 2021)

Bar Memberships

Hale is licensed to practice law in the following states:

Georgia
Texas
Florida
Washington, D.C.

Court Admissions

Hale is admitted to practice before several federal courts:

U.S. Tax Court
U.S. Court of Federal Claims
U.S. Court of Appeals, Federal Circuit
U.S. Court of Appeals, Fourth Circuit
U.S. Court of Appeals, Fifth Circuit
U.S. Court of Appeals, Eleventh Circuit
U.S. District Court – Middle District of Georgia
U.S. District Court – Northern District of Georgia
U.S. Court of International Trade

Citations as Authority - Tax and Law Journals

In addition to publishing a long list of articles, Hale has been cited by others as a tax/legal authority in many prestigious journals over the years, such as:

Harvard Law Review
Yale Law Journal
Columbia Law Review
New York University Tax Law Review
Virginia Tax Review
Florida Tax Review
The Tax Lawyer
Michigan Journal of International Law
George Washington International Law Review
Georgetown International Environmental Law Review
Fordham Urban Law Journal
UCLA Law Review
Northwestern Journal of Criminal Law and Criminology
Boston College Law Review
California Western International Law Journal
Washington University Global Studies Law Review
Pittsburgh Journal of Law and Commerce
Wisconsin International Law Journal
DePaul Law Review
Georgetown Law and Policy in International Business
Texas Law Review
Suffolk Law Review
Thomas M. Cooley Law Review
South Texas International Trade Law Journal
Columbia Journal of Transnational Law
Air Force Law Review
San Diego International Law Journal
Southwestern University Journal of Law and Trade in the Americas
Florida Journal of International Law
Loyola International and Comparative Law Review
Colorado Journal of International Environmental Law and Policy
University of Denver Transportation Law Journal
American University International Law Review
UCLA Journal of Environmental Law and Policy
North Carolina Journal of International Law and Commercial Regulation
University of California-Davis Law Review
Wake Forest Law Review
University of California-Hastings Law Journal
Southern Methodist University Law Review
New Mexico Law Review
Case Western Reserve Canada-United States Law Journal
Washington Pacific Rim Law and Policy Journal
Texas Tech Journal of Administrative Law
Fordham International Law Journal
Minnesota Law Review
Northwestern Journal of International Law and Business
University of California-Davis Journal of International Law and Policy
Tulsa Journal of Comparative and International Law
New York International Law Review
Southern Methodist University Law and Business Review of the Americas
University of the Pacific Transnational Lawyer
Widener University Law Review
Revista Juridica Universidad de Puerto Rico
Brooklyn Journal of International Law
Tulane Journal of International and Comparative Law
University of Cincinnati Immigration and Nationality Law Review
Florida State Journal of Transnational Law and Policy
Berkeley Journal of International Law
Boston College International and Comparative Law Review
American Journal of International Law
Syracuse Law and Technology Journal
International Business Lawyer
Georgia Law Review
Journal of International Economic Law
Ohio State Law Journal
Catholic University Law Review
Pace International Law Review
Texas International Law Journal
S. Joint Committee on Taxation Report
University of Connecticut Insurance Law Journal
New York University Law Review
Columbia Business Law Review
Villanova Law Review
Houston Journal of International Law
Cornell International Law Journal
Fordham Law Review
National Taxpayer Advocate Report to Congress
Federal Circuit Bar Journal
Fordham Intellectual Property, Media, and Entertainment Law Journal
DePaul Business and Commercial Law Journal
Michigan State Law Review
Penn State Law Review
Journal of International Commercial Law and Technology
University of California-Davis Business Law Journal
University of Buckingham Denning Law Journal
Hofstra University Journal of International Business and Law
Georgetown Journal of Law and Public Policy
Denver Journal of International Law and Policy
Chapman Law Review
Korean Estate, Tax, and Personal Financial Planning Journal
California Journal of Tax Litigation
Boston University Review of Banking and Financial Law
Worldwide Tax Daily
Tax Notes Today
Washington Law Review
Fordham Journal of Corporate and Financial Law
Kansas Law Review
George Washington University Public Contract Law Journal
Texas Tax Lawyer
William & Mary Business Law Review
Washington University (St. Louis) Law Review
Michigan State Journal of Business and Securities Law
Austrian Review of International and European Law
Singapore Journal of Legal Studies
European Business Law Review
United Nations Commission on International Trade Law Yearbook
Colorado Natural Resources, Energy & Environmental Law Review
Estate Planning Journal
Connecticut Law Review
Southern Law Journal
Loyola Consumer Law Review
Journal of International Taxation
Australian Yearbook of International Law
California State University Tax Development Journal
Osgoode Hall Law Journal
International Business Lawyer
Zbornik pravnog Fakulteta Sveučilišta u Rijeci (Croatia)
Columbia Journal of Tax Law
Public Contract Law Journal
Minnesota Journal of International Law
Georgia State University Law Review
Global Jurist
University of Missouri Business, Entrepreneurship, and Tax Law Review
Journal of Taxation and Regulation of Financial Institutions
International Enforcement Law Reporter
Belmont University Law Review
Canadian Tax Journal
William and Mary Environmental Law and Policy Review
University of California-Hastings International and Comparative Law Review
Probate & Property Journal
Pittsburgh Tax Review
University of Cincinnati Law Review
Pepperdine Journal of Business, Entrepreneurship and the Law
Rutgers Computer and Technology Law Journal
Estates, Trusts & Pensions Journal
George Mason University Law Review
University of Indiana Law Journal
University of Texas Environmental Law Journal

Citations as Authority - Court Submissions

Hale has also been cited in legal briefs filed by taxpayers in the following federal courts:

U.S. Court of Federal Claims
U.S. Court of Appeals, Third Circuit
U.S. Court of Appeals, Fifth Circuit
U.S. Court of Appeals, Sixth Circuit
U.S. Court of Appeals, Ninth Circuit
U.S. District Court, New Jersey
U.S. District Court, Southern District of New York
U.S. District Court, Utah

Citations as Authority - Books

In addition to being referenced as a tax/legal expert in a long list of journals, Hale has also been cited in various books, such as:

Tax Controversies: Practice and Procedure, Carolina Academic Press.
Effectively Representing Your Client Before the IRS, American Bar Association.
Tax Fraud and Evasion: Money Laundering, Asset Forfeiture, Sentencing, WG&L.
Going Global: A Guide to Building an International Business, Thomson Reuters.
International Tax as International Law: An Analysis of the International Tax Regime, Cambridge University Press.
Tax Planning with U.S. Holding Companies - Repatriation of Profits from Europe, Kluwer Law International.
NAFTA Revisited: Achievements and Challenges, Institute for International Economics.
World Trade Organization Agreement on Anti-Dumping, Kluwer Law International.
Research Handbook in International Economic Law, Edward Elgar Publishing.
Normative Conditions to Make WTO Law More Responsive to the Needs of Developing Countries, Herbert Utz Verlag GmbH.
Latin American Law: A History of Private Law and Institutions in Spanish America, University of Texas Press.
Migrants or Expatriates? Americans in Europe, Palgrave MacMillan Ltd.
Sovereignty, the WTO, and Changing Fundamentals of International Law, Cambridge University Press.
International Tax Evasion in the Global Information Age, Palgrave MacMillan Ltd.
The Economic Dynamics of Environmental Law, MIT Press
Global Perspectives on Income Tax Law, Oxford University Press
Advance Introduction to International Tax Law, 2nd Edition, Edward Elgar Publishing
SIMPLE, SEP and SARSEP Answer Book, Wolters Kluwer.
Valuing Intellectual Capital: Multinationals and Tax Havens, Springer New York.
Public Land and Resources Law Digest, Rocky Mountain Mineral Law Foundation.
Tax, Estate & Financial Planning for the Elderly, Lexis Nexis.
Strategic Management of Health Care Organizations, Wiley & Co.
Migrants or Expatriates? Americans in Europe, Palgrave MacMillan Ltd.
The First Decade of NAFTA: The Future of Free Trade, Transnational Publishers.
Taxation and Migration, Wolters Kluwer.
Taxation of International Transactions: Materials, Text, and Problems, Thomson West.
Tax Planning for Domestic and Foreign Partnerships, Practising Law Institute.

Professional Affiliations

Journal of International Taxation, Board of Advisors
Journal of Taxation, former Editorial Board member and tax columnist
IRS-Practitioner Liaison Committee, Georgia Bar representative
Journal of Tax Practice & Procedure, Editorial Board member
Georgia Bar Tax Section, former President
Georgia Bar Journal, former Editorial Board member
GSU Low-Income Taxpayer Clinic, Advisory Committee member
Georgia Council for International Visitors, Citizen Diplomat
American Bar Association, Tax Section, Member
Atlanta Bar Association, Tax Section, Board of Directors
American Citizens Abroad, Former Tax Advisory Council member
Latin American Association, Member
World Trade Center Atlanta, Member
Southern Capital Forum, Member
Law360 Tax Authority International, Editorial Board

News

87 Chamberlain Hrdlicka Attorneys Named to 2025 Best Lawyers in America®
Best Lawyers in America® recognizes 87 Chamberlain Hrdlicka attorneys in a peer selection process for the 2025 edition of Best Lawyers in America
August 15, 2024
Chamberlain Hrdlicka Improves Rankings in Chambers & Partners 2024 USA Guide
Chamberlain Hrdlicka ranked in the top ten tax law firms in the United States
July 11, 2024
Chamberlain Hrdlicka Attorneys Named Among The Best in 2024 Georgia Super Lawyers, Rising Stars
2024 Georgia Super Lawyers includes Chamberlain Hrdlicka Attorneys
February 8, 2024
Chamberlain Hrdlicka Shareholder Hale Sheppard Named Forbes Contributor
Atlanta Shareholder Hale Sheppard Named Forbes Contributor
January 23, 2024
87 Chamberlain Hrdlicka Attorneys Named to 2024 Best Lawyers in America®
Best Lawyers in America® recognizes 87 Chamberlain Hrdlicka attorneys in a peer selection process for the 2024 edition of Best Lawyers in America
August 17, 2023
Chamberlain Hrdlicka Maintains Top Tax Law Firm and Enhances Individual Legal 500 Rankings
Legal 500 ranks David Aughtry and Larry Campagna in its Hall of Fame, Jaime Vasquez and Juan Vasquez Jr rank as Leading Lawyers in US: Tax Contentious Category
June 12, 2023
Chamberlain Hrdlicka Improves Practice and Individual Rankings in Chambers & Partners 2023 USA Guide
Chamberlain Hrdlicka ranked in the top ten U.S. tax law firms by Chambers & Partners
June 2, 2023
Chamberlain Hrdlicka Attorneys Named Among The Best in 2023 Georgia Super Lawyers, Rising Stars
David Aughtry, Stephanie Friese Aron, Sandy Bradford, Seth Price, Hale Sheppard, Erica Opitz, Patrick McCann, Jr., John Kirbo, John Guin, and Chadd Reynolds named as Georgia Super Lawyers, Rising Stars
February 9, 2023
72 Chamberlain Hrdlicka Attorneys Named to US News – 2023 Best Lawyers in America®
Best Lawyers in America® recognizes 72 Chamberlain Hrdlicka attorneys in a peer selection process for the 2023 edition of Best Lawyers in America
August 18, 2022
Hale Sheppard recognized as Lawyer of the Year in Tax and Tax Litigation and Controversy in Atlanta by Best Lawyers in America®
Atlanta attorneys voted for Hale Sheppard as 2023 Lawyer of the Year in Tax and Tax Litigation and Controversy through US News' Best Lawyers in America®
August 18, 2022
Chamberlain Hrdlicka Ranks in Top Ranked Legal
Chamberlain Hrdlicka Ranks in Top Ranked Legal for Tax and Immigration
July 19, 2022
Chamberlain Hrdlicka Maintains Top Tax Law Firm and Enhances Individual Legal 500 Rankings for 2022
Legal 500 rankings for Chamberlain Hrdlicka as a Top Tax Law Firm and Adds to Individual Ranks in 2022
June 17, 2022
Chamberlain Hrdlicka Maintains Practice and Enhances Individual Rankings in Chambers & Partners 2022 USA Guide
Chamberlain Hrdlicka ranked in the top ten U.S. tax law firms by Chambers & Partners 2022 USA Guide
June 2, 2022
Eight Chamberlain Hrdlicka Lawyers Named Among 2022 Georgia Super Lawyers, Rising Stars
David Aughtry, Stephanie Friese Aron, Seth Price, Hale Sheppard, Erica Opitz, John Kirbo, John Guin, and Barclay Taylor named as Georgia Super Lawyers, Rising Stars
February 15, 2022
54 Chamberlain Hrdlicka Attorneys Named to 2022 Best Lawyers in America®
Best Lawyers in America® selects 54 Chamberlain Hrdlicka Attorneys for Recognition for 2022
August 19, 2021
Chamberlain Hrdlicka Maintains Top Tax Law Firm and Individual Legal 500 Rankings
Legal 500 Firm and Individual Rankings Improve at Chamberlain Hrdlicka for 2021
June 21, 2021
Chamberlain Hrdlicka enhances Practice and Individual Rankings in Chambers & Partners 2021 USA Guide
Chambers & Partners 2021 List for Chamberlain Hrdlicka Practice and Individual Rankings
June 3, 2021
“Hale Sheppard Elected to Law360's 2021 Tax Authority International Advisory Board”
Law360 Tax Authority International Advisory Board elects Hale Sheppard to the Board
Law360, April 23, 2021
Twelve Chamberlain Hrdlicka Lawyers Named among 2021 Georgia Super Lawyers, Rising Stars
Super Lawyers names Chamberlain Hrdlicka attorneys as 2021 Georgia Super Lawyers and Rising Stars
February 12, 2021
Record 53 Chamberlain Hrdlicka Attorneys Named to US News – 2021 Best Lawyers in America®
Chamberlain Hrdlicka Attorneys Named to US News – 2021 Best Lawyers in America®, Three Attorneys Recognized as Lawyer of the Year
August 20, 2020
Paycheck Protection Program (PPP) Loan Forgiveness Tax Issues
Chamberlain Hrdlicka Tax Alert - Paycheck Protection Program (PPP) Loan Forgiveness Tax Issues
May 21, 2020
Chamberlain Hrdlicka continues to be recognized with Practice and Individual Rankings by Chambers & Partners
Chambers Individual and Practice Rankings for 2020
May 4, 2020
Ten Chamberlain Hrdlicka Attorneys Named Among 2020 Georgia Super Lawyers and Rising Stars
2020 Georgia Super Lawyers and Rising Stars Named at Chamberlain Hrdlicka
March 4, 2020
Chamberlain Hrdlicka 34th Annual Atlanta Tax and Business Planning Seminar - November 12 at Crowne Plaza Ravinia
November 12, 2019
Record Number of Chamberlain Hrdlicka Attorneys Named to US News 2020 Best Lawyers in America® and Four Attorneys Recognized as Lawyer of the Year
August 15, 2019

Presentations

Seminars & Presentations

Chamberlain Hrdlicka Complimentary Webinar: IRS Implements Employee Retention Credit Voluntary Disclosure Program
Highlights of the ERC Voluntary Disclosure Program Complimentary Webinar presented by Chamberlain Hrdlicka
January 4, 2024
Chamberlain Hrdlicka 34th Annual Atlanta Tax and Business Planning Seminar - November 12 at Crowne Plaza Ravinia
November 12, 2019

Speaking Engagements

Hale is a frequent speaker on tax topics, having presented before the following groups:

Southern Federal Tax Institute
American Institute on Federal Taxation
Tennessee Federal Tax Conference
Southeastern Accounting Show
Georgia Federal Tax Conference
Alabama Federal Tax Clinic
Chattanooga Tax Practitioners
Birmingham Tax Forum
South Carolina Tax Summit
Georgia Estate Planning Conference
Georgia Tax Forum
North Carolina/South Carolina/Georgia Tax Section Seminar
North Atlanta Tax Council
Macon Estate Planning Council
Central Georgia Estate Planning Council
National Association of Tax Professionals
National Association of Enrolled Agents
Atlanta Bar Association
Georgia Association of Enrolled Agents
Institute of Continuing Legal Education
American Society of Women Accountants
Atlanta Association of Former IRS Agents
Technology Association of Georgia
American Association of Daily Money Managers
Florida Society of Enrolled Agents
American Women's Society of CPAs
Georgia Fraud and Forensic Accounting Conference
IRS Solutions Conference
Financial Planning Association of Georgia
North Carolina Bar Association Tax Section
University of San Diego International Tax Institute
Louisiana Tax Conference
Florida Tax Institute
Georgia Decision-Makers Conference
South Carolina Society of CPAs Spring Conference
ATA Annual Tax Conference
University of Akron National Tax Conference
National Conference of CPA Practitioners Accounting & Tax Symposium
Atlanta Tax Forum
Wisconsin Institute of CPAs Accounting and Auditing Conference
University of Texas Taxation Conference
Virginia Law Foundation
Colorado Society of CPAs
Louisiana Society of CPAs
Washington Society of CPAs
Great Plains Federal Tax Institute
Heart of America Tax Institute
Pacific Tax Institute
Society of Financial Service Professionals Institute

Publications

Tax Publications

Hale ranks among the most active tax writers in the country, having published more than 280 major articles in top law reviews and tax journals. A partial list of his articles is set forth below.

Exploring Four Recent IRS Enforcement Campaigns on Charitable Donations, ___ TAX NOTES FEDERAL ___ (2025).
Foreign Gift Reporting Disputes: Exploring Three New Cases and an IRS Policy Shift, __ INTERNATIONAL TAX JOURNAL __ (2025).
What $1 Can Get You: Expanding Standards for “Qualified Offers” in Tax Disputes, ___ ___ TAXES — THE TAX MAGAZINE ___ (2025).
Compiling 10 Obscure Issues as FBAR Battles Mature, __ JOURNAL OF TAXATION ___ (2024); republished in ___ JOURNAL OF INTERNATIONAL TAXATION___ (2024).
Five New Events in 2024 Affecting Employee Retention Credit Disputes, ___ TAX NOTES FEDERAL ___ (2024).
Third Case on Allocation among Designers of Section 179D Deductions for Energy Efficient Commercial Property, ___ JOURNAL OF TAXATION __ (2024).
Altered, Backdated and Inconsistent Documents Not Enough for Fraud, ___ TAX NOTES FEDERAL ___ (2024).
Improper ERC Claims: IRS vs. Taxpayers vs. Payroll Companies, ___ TAX NOTES FEDERAL ___ (2024).
A Look at the Second ERC Voluntary Disclosure Program, 185(4) TAX NOTES FEDERAL 697 (2024).
Surprising New FBAR Cases: A Mixed Bag for Taxpayers Facing Foreign Account Penalties, __ JOURNAL OF TAXATION ___ (2024); republished in ___ JOURNAL OF INTERNATIONAL TAXATION___ (2024).
Evaluating Three Conservation Easement Settlement Offers, 184(6) TAX NOTES FEDERAL 1083 (2024).
How the IRS Can Recapture ERC Refunds and Interest, ___ TAX NOTES FEDERAL ___ (2024).
Erroneous Refund Suits for ERCs and Effects of Novel Case, ___ TAX NOTES FEDERAL ___ (2024).
Exploring Recent Cases and IRS Guidance on Unique International Disclosure Duties for Dual Residents, ___ INTERNATIONAL TAX JOURNAL 40 (2024).
The Latest on Foreign Trusts: Enforcement Actions, Relief Measures, New Cases, Proposed Regulations, and More, ___ INTERNATIONAL TAX JOURNAL ___ (2024).
Expatriation, Form 8854, Invalidation of IRS Notice, and Next Steps, ___ INTERNATIONAL TAX JOURNAL ___ (2024).
Administrative, Legislative and Executive Actions to Address ERC Claims, ___ TAX NOTES FEDERAL ___ (2024).
Private Placement Life Insurance: Potential Tax Changes and Reasons Why, __ JOURNAL OF TAXATION ___ (2024); republished in __ PRACTICAL TAX STRATEGIES __ (2024); republished in ___ESTATE PLANNING __ (2024).
A Comprehensive Look at ERC Enforcement Tactics So Far, 183 TAX NOTES FEDERAL 1729 (2024).
Improper ERC Claims: Liability for Third Party Payers, Employers, Both? , ___ TAX NOTES FEDERAL ___ (2024).
CRATs as Listed Transactions? Analyzing IRS Actions and Taxpayer Options, ___ TAX NOTES FEDERAL ___ (2024).
IRS Attempts to Reduce Warnings to Taxpayers about Making Third Party Contacts, ___ TAXES — THE TAX MAGAZINE ___ (2024); republished in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2024).
IRS Wins on Inventory Issue in Three Conservation Easement Cases, 183 (7) TAX NOTES FEDERAL 1213 (2024).
Conservation Easement Settlement Initiatives in 2020 and 2024, ___ TAX NOTES FEDERAL ___ (2024).
New Case Shows Strategic Considerations in “Cooperating” with IRS Audits, ___ TAXES — THE TAX MAGAZINE ___ (2024); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2024).
Employee Retention Credits: How Fraud by Preparers Could Affect Taxpayers, ___ TAX NOTES FEDERAL ___ (2024).
Employee Retention Credits: Probing the Strength of IRS Penalty Threats, ___ TAX NOTES FEDERAL ___ (2024).
More on IRS Strategies to Reopen Closed Assessment Periods, __ JOURNAL OF TAXATION __ (2024); republished in __ JOURNAL OF INTERNATIONAL TAXATION __ (2024).
ERC Claims as Reportable Transactions: Threats, Consequences, and Defenses, ___ TAX NOTES FEDERAL ___ (2024).
ERCs and “Protective” Amended Income Tax Returns, ___ TAX NOTES FEDERAL ___ (2024).
Comparing IRS Settlements: Easements and Employee Retention Credits, ___ TAX NOTES FEDERAL ___ (2024).
ERC Challenges to the IRS, by the IRS, and among Various Parties, ___ TAX NOTES FEDERAL ___ (2024).
ERC Enforcement Tactics: Analyzing the IRS’s Carrots and Sticks So Far, ___ TAX NOTES FEDERAL ___ (2024).
IRS Tries to Further Limit ERC Claims under Governmental Order Test, ___ TAX NOTES FEDERAL ___ (2024).
Tax Court Says “As Such” Means Much: Early IRS Victory in Battle over SECA Taxes and Limited Partners,”__ JOURNAL OF TAXATION __ (2024); republished in ___ PRACTICAL TAX STRATEGIES ___ (2024); republished in ___ TAXATION OF EXEMPTS __ (2024); republished in __ CORPORATE TAXATION ___ (2024).
Aroeste v. United States: Narrow FBAR Dispute Generates Broad Victories for All Taxpayers, ___ TAXES — THE TAX MAGAZINE ___ (2024); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2024).
Valuation Loss in Recent Easement Case Obscures Silver Linings, ___ TAX NOTES FEDERAL ___ (2023).
Foreign Gifts and Foreign Trusts: Taxpayers Still Seeking Court Guidance after Two Government Concessions, 101(12) TAXES — THE TAX MAGAZINE ___ (2023).
IRS Attacks on Art Donations: Old Techniques, New Hurdles, __ TAX NOTES FEDERAL __ (2023).
Comparing Consequences of Obtaining Improper PPP and ERC Benefits: Taxpayers Might Be Surprised, ___ JOURNAL OF TAXATION __ (2023); republished in ___ PRACTICAL TAX STRATEGIES ___ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ CORPORATE TAXATION ___ (2023).
Employee Retention Credits: What the IRS Did Not Do, Did Do, and Might Do, 181(4) TAX NOTES FEDERAL 619 (2023).
Employee Retention Credits: Success Requires Mastery of Procedural and Substantive Rules, __ TAX NOTES FEDERAL __ (2023).
Employee Retention Credits: Exploring Reasons for Prolonged Claims, __ TAX NOTES FEDERAL __ (2023).
Employee Retention Credits: IRS Clarifies Limited Eligibility of Federal Credit Unions, 180(10) TAX NOTES FEDERAL 1615 (2023).
Employee Retention Credits: Issues Arise as Finger-Pointing Begins, __ TAX NOTES FEDERAL __ (2023).
Employee Retention Credits: Government Orders, Suspended Operations, and Supply Chains, 180(9) TAX NOTES FEDERAL 1413 (2023).
Employee Retention Credits: Analyzing Key Issues for “Promoters” and other “Enablers,” __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023).
Employee Retention Credits: Analyzing Key Issues for Taxpayers Facing IRS Audit, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023).
Employee Retention Credits: Analyzing Congressional and IRS Guidance from Start to Finish, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023).
Character Counts: IRS Shifts Focus to Original Landowners in Conservation Easement Disputes 7(180) TAX NOTES FEDERAL 1077 (2023).
California's Settlement Initiative for Conservation Easements, 180(4) TAX NOTES FEDERAL 543 (2023).
IRS Calls Treaty-Based Positions for Malta Pensions Listed Transactions, 111(28) TAX NOTES FEDERAL 169 (2023).
The IRS Challenges Gifts to and from Foreign Persons: Analyzing Two Recent Victories for Taxpayers, ___ INTERNATIONAL TAX JOURNAL 31 (2023); reprinted in ___ TAXES — THE TAX MAGAZINE ___ (2023).
The Unavoidable Overlap of Promoter Investigations and Taxpayer Audits: Interactions and Insights __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Holy CRAT! Exploring Options for Taxpayers after Early Tax Court Losses ___ TAX NOTES FEDERAL __ (2023).
IRS Claims It Can Revive Closed Assessment-Periods in International Tax Disputes, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF INTERNATIONAL TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
IRS Issues Safe Harbors for Easement Deeds: Technical Battles Will Persist, __ TAX NOTES FEDERAL ___ (2023).
Tax Court Rules that IRS Cannot Assess and Collect Form 5471 Penalties: Many Questions Triggered by Novel Ruling, ___ INTERNATIONAL TAX JOURNAL ___ (2023).
Easement Evolution: Proposed Regulations, New Law, and Public Comments, __ TAX NOTES FEDERAL ___ (2023).
Canadian Retirement Plans and Accounts: Evolving Special Rules and Enduring IRS Problems, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF INTERNATIONAL TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
IRS Concedes First Case of Form 3520 Penalties for Unreported Foreign Gifts: A Bittersweet Victory, __ TAX NOTES FEDERAL ___ (2023).
Foreign Trusts, Foreign Gifts and Ongoing Disputes: Public Comments and Possible Changes, ___ INTERNATIONAL TAX JOURNAL ___ (2023).
Does Residency Status under a Treaty Affect FBAR Duties? District Court Order Ponders Potential “Escape Hatch” for Taxpayers, ___ INTERNATIONAL TAX JOURNAL ___ (2023).
Novel Case Shows Social Media Might Jeopardize Tax Relief, 179(1) TAX NOTES FEDERAL 59 (2023).
IRS Still Mining for Foot Faults in Conservation Easement Cases? Tax Court Takes Step in Right Direction, ___ TAX NOTES FEDERAL ____ (2023).
Is the “Ultimate Tax Plan” Nearing Ultimate Rejection by the Tax Court? ___ TAX NOTES FEDERAL ____ (2023).
IRS Introduces New Challenge to Tax-Related Insurance: From Easements to Elsewhere, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Energy Efficient Commercial Building Property and Section 179D: New Tax Court Case Offers Guidance on Allocation of Deductions, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in ___ TAXATION OF EXEMPTS __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Same Standard, Different Taxes: The IRS and New York Attack Limited Partner Exception, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF CORPORATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
An Oldie But Not a Goodie: Putting a New Conservation Easement Case into Perspective, ___ TRUST & ESTATES JOURNAL __ (2023).
The IRS Takes Another Crack at Demonizing Easement Donations: Proposed Regulations and New Focus on Land Trusts, __ TAXATION OF EXEMPTS ___ (2023); republished in __ REAL ESTATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
Revenue Procedure 2022-39: Collaboration Salvages Special Penalty-Avoidance Rules for Large Entities, ___ TAXES — THE TAX MAGAZINE ___ (2023); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2023).
The Accuser Becomes the Accused in the Conservation Easement Context: Courts Hold that IRS Violated the Law in Green Valley Investors and Elsewhere, __ JOURNAL OF TAXATION ___ (2023); republished in __ REAL ESTATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
So Close, Yet So Far Away, from the Desired Tax Result: Three Recent Cases Showing Pivotal Role of Closing Agreements ___ TAXES — THE TAX MAGAZINE ___ (2023); reprinted in ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2023).
Tax Court Showdown over SECA Taxes and Limited Partners: Exploring the Catalyst for the Second Case of Many, __ JOURNAL OF TAXATION ___ (2023); republished in __ JOURNAL OF CORPORATE TAXATION __ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023).
Glade Creek and Champions Retreat: New Cases Bolster Special Conservation Easement Valuation Methods, ____ TAX NOTES FEDERAL ___ (2022).
Harbingers of More IRS Enforcement of Repatriation/Transition Taxes, ____ TAXES — THE TAX MAGAZINE 41 (2022); republished _____ INTERNATIONAL TAX JOURNAL ___ (2022).
Extreme IRS Actions Fortify Taxpayer Disclosure Defenses in Conservation Easement Disputes, __ JOURNAL OF TAXATION ___ (2023); republished in __ PRACTICAL TAX STRATEGIES __ (2023); republished in __ REAL ESTATE TAXATION __ (2023).
Foreign Gifts, Forms 3520, Big Penalties, and a Pending Case 177(1) TAX NOTES FEDERAL 57 (2022); republished in 108(1) TAX NOTES INTERNATIONAL 45 (2022).
Bait and Switch? Multi-Case Dispute Shows Risks of Participating in Certain IRS Disclosure Programs, _____ INTERNATIONAL TAX JOURNAL ___ (2022).
Recent Court Rulings Confirm Proper Conservation Easement Valuation Method: Highest and Best Use, Before and After Method, and Discounted Cash-Flow Analysis. ___ TAX NOTES FEDERAL ___ (2022).
Tax Incentives, Economic Substance, and Partnership Validity: New Case Undercuts IRS Attacks by IRS, __ JOURNAL OF TAXATION ___ (2022); republished in __ JOURNAL OF ORPORATE TAXATION __ (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in __ TAXATION OF EXEMPTS __ (2022).
Opportunity Zones, Late Elections, and New Enforcement and Oversight Actions, 137(5) JOURNAL OF TAXATION 3 (2022); republished in __ JOURNAL OF CORPORATE TAXATION __ (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in __ TAXATION OF EXEMPTS __ (2022); republished in _ REAL ESTATE TAXATION __ (2022).
New Case Illustrates Permanent Effect of Concessions Made by the IRS or Taxpayers during a Tax Dispute, ___ TAXES — THE TAX MAGAZINE __ (2022).
Involuntary Disclosure by the IRS about Voluntary Disclosure Program for Taxpayers: Analyzing the Fourth Round of Guidance, __ INTERNATIONAL TAX JOURNAL ___ (2022); republished in ___ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2022).
New Tax Court Case Shows that the IRS Is Getting “Sirius” about SECA taxes and the Limited Partner Exception, __ CORPORATE TAXATION __ (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in __ TAXATION OF EXEMPTS __ (2022).
Opportunity Zones, Tax Benefits, Criticisms, and Early IRS Enforcement, 137(4) JOURNAL OF TAXATION 3 (2022); republished in 49(5) CORPORATE TAXATION 3 (2022); republished in 109(5) PRACTICAL TAX STRATEGIES __ (2022); republished in 34(2) TAXATION OF EXEMPTS 6 (2022); republished in _ REAL ESTATE TAXATION __ (2022).
Expedited Challenges to Economic Substance: Exposure for Taxpayers and Problems for the IRS, __ JOURNAL OF TAXATION 3 (2022); republished in __ PRACTICAL TAX STRATEGIES __ (2022); republished in _ REAL ESTATE TAXATION __ (2022).
The Rise and Fall of Malta Pensions: Taxpayer Positions, IRS Enforcement, and Remaining Solutions, ___ TAX NOTES FEDERAL ___ (2022); republished in ___ TAX NOTES INTERNATIONAL ___ (2022).
Improper Disclosures of Taxpayer Data by the IRS under Section 6103: Recovering Punitive Damages Despite No Actual Damages, _ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022).
Small Employment Tax Case Triggers Big Ruling for All Voluntary Disclosure Programs, (2022).
Valuation, Highest and Best Use, and Conservation Easements: New IRS Attacks of Old Appraisal Methods, ___ TAX NOTES FEDERAL ___ (2022); republished in 2022 TAX NOTES TODAY ____ (2022).
Expatriating Taxpayers and Unfiled Forms 8854: Administration Proposes Disparate Treatment Based on Financial Status, ___ INTERNATIONAL TAX JOURNAL ___ (2022).
Replacing Sticks with Carrots When It Comes to Tax Disclosures? New Proposals regarding Form 8275-R, _ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___ TAXATION OF EXEMPTS ___ (2022).
IRS Announces Newest Version of its Comprehensive Voluntary Disclosure Program: Analyzing the Evolution Over Five Years, ___ INTERNATIONAL TAX JOURNAL ___ (2022).
Recent Refund Case Shows Primacy of Tax Procedure, ___PRACTICAL TAX STRATEGIES __ (2022); republished in ____ TAXATION OF EXEMPTS __ (2022).
New Tax Court Case Explores Boundaries of “Qualified Offers” to the IRS, ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2022); republished in ___ TAXES — THE TAX MAGAZINE ___ (2022).
International Tax Non-Compliance, Exit Taxes, Special Treatment for Accidental Americans, and Urgency Created by Recent Whistleblower Actions, ___ INTERNATIONAL TAX JOURNAL __ (2022).
New Rules in 2022 for Litigating Worker Classification and Section 530 Relief Cases in Tax Court, 24(1) JOURNAL OF TAX PRACTICE & PROCEDURE 51 (2022).
Comparing Federal and State Proposals for Resolving Conservation Easement Disputes, ___TAXATION OF EXEMPTS ___ (2022); republished in _ JOURNAL OF REAL ESTATE TAXATION __ (2022).
Analyzing Obstacles for the IRS in Approaching Partners During Partnership Tax Disputes, _ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___TAXATION OF EXEMPTS ___ (2022); republished in _ JOURNAL OF REAL ESTATE TAXATION __ (2022).
Case Shows Tricky Issues with Making “Deposits” with the IRS to Stop Interest Accrual during Lengthy Tax Disputes, __ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___TAXATION OF EXEMPTS ___ (2022); republished in _ JOURNAL OF REAL ESTATE TAXATION __ (2022).
Series of Tax Court Orders Allowing Nonconsensual Depositions by IRS: Aberration or Trend? ____ TAXES — THE TAX MAGAZINE ___ (2022).
Achtung with Your Stiftung: Evolving Concept of Foreign Trusts and Potential Relief for Taxpayers, __ JOURNAL OF INTERNATIONAL TAXATION ___ (2022); republished in ___ __ JOURNAL OF TAXATION ___ (2022); republished in ___PRACTICAL TAX STRATEGIES __ (2022); republished in ___ESTATE PLANNING ___ (2022).
No Notice, No Examination, No Problem: IRS Further Abolishes Procedural Protections for Appraisers, ___ JOURNAL OF REAL ESTATE TAXATION ___ (2022); republished in ___TAXATION OF EXEMPTS ___ (2022); republished in ___ESTATE PLANNING ___
(2022); republished in ___JOURNAL OF TAXATION ___ (2022).
Reasonable IRS Appraisal Triggers Conservation Easement Settlement, 174(1) TAX NOTES FEDERAL 55 (2022); republished in 2022 TAX NOTES TODAY 13-10 (2022).
Section 179D Deduction for Energy Efficient Commercial Building Property: IRS Attacks Allocations as Part of Compliance Campaign, ___ JOURNAL OF TAXATION __ (2022); republished in __ JOURNAL OF REAL ESTATE TAXATION __ (2022).
IRS Disputes Which “Limited Partners” Escape SECA Taxes Under Section 1402, ___ JOURNAL OF CORPORATE TAXATION ___ (2022).
Heads the IRS Wins, Tails the Taxpayers Lose: Analyzing Inconsistent Positions on the Meaning of “Limited Partners” ___ JOURNAL OF CORPORATE TAXATION ___ (2022).
Analyzing the Long Journey to Chaos: SECA Taxes, Limited Partner Exception, and Effects of Government Inaction, ___ JOURNAL OF CORPORATE TAXATION ___ (2021).
IRS Suffers Second Court Loss for Failing to Properly Warn Taxpayers about Third-Party Contacts during Audits, ___TAXES __(2021); ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2021).
Can Foreign Tax Credits Offset Net Investment Income Taxes? Tax Court Holds that It Depends on the Treaty, ___ JOURNAL OF INTERNATIONAL TAXATION __ (2021); PRACTICAL TAX STRATEGIES __ (2021).
The IRS “Stacks” International Penalties in Foreign Trust Disputes: Two Recent Cases and Earlier IRS Guidance Reveal the Playbook, 99(11) TAXES — THE TAX MAGAZINE ___ (2021).
International Tax Disputes: Recent Cases Show Ways Taxpayers Give the IRS Forever to Audit, Tax and Penalize, 47(6) INTERNATIONAL TAX JOURNAL __ (2021).
Are the IRS’s Positions “Substantially Justified?” New Cases Clarify Standards for Reimbursements to Taxpayers under Section 7430, ___ PRACTICAL TAX STRATEGIES __ (2021); republished in ___ JOURNAL OF TAXATION __ (2021).
Recent Tax Court Case Reveals Rare Use of Form 5471 Penalty Defenses, 47(5) INTERNATIONAL TAX JOURNAL __ (2021).
Neither Death Nor Distance Erases the Issues: IRS Actions against Deceased or Absconding Taxpayers, ___ JOURNAL OF INTERNATIONAL TAXATION __ (2021); republished in __ ESTATE PLANNING __ (2021).
Here Comes the Tax Enforcement, There Go the Passports: Analyzing the Evolution of Section 7345 during Its First Five Years, ___ TAXES — THE TAX MAGAZINE ___ (2021).
30 Wrongs Do Not Make A Right: Revealing Extraordinary IRS Actions in Conservation Easements Disputes, ___ TAXATION OF EXEMPTS ___ (2021); republished in ___ JOURNAL OF TAXATION ___ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021).
Recent Case Highlights Converge of Substance and Procedure in International Tax Disputes, ___ JOURNAL OF INTERNATIONAL TAXATION ___ (2021); republished in ___ JOURNAL OF TAXATION ___ (2021).
It’s Not Over Till It’s Over: Lessons from Crandall about Closing Agreements and Key Procedural Issues in Tax Disputes, ____ INTERNATIONAL TAX JOURNAL __ (2021).
Disputing FBAR Penalties: Mendu Case Clarifies How Much Taxpayers Must Pay to Play, ____ INTERNATIONAL TAX JOURNAL __ (2021).
Can the IRS Really Do That? Third Party Contacts, Notification Duties, Reprisal Exception, and More, ___ JOURNAL OF TAX PRACTICE & PROCEDURE __ (2021).
Three New IRS Challenges to Tax Result Insurance in Conservation Easement Disputes, __ JOURNAL OF TAXATION __ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021); republished __TAXATION OF EXEMPTS ___ (2021).
Harsh Consequences of Late Forms 1120-F, New Tax Court Case, and Solutions Still Available to Foreign Corporations, __ INTERNATIONAL TAX JOURNAL __ (2021); republished in ___ TAXES — THE TAX MAGAZINE __ (2021).
Court Overturns Legendary FBAR Case, Bedrosian, But Government Settlement Elsewhere Encourages Taxpayers with Foreign Account Issues, ___ INTERNATIONAL TAX JOURNAL __ (2021).
20 Recent IRS Enforcement Actions in Conservation Easement Disputes: Awareness and Preparation Are Key, __ JOURNAL OF TAXATION __ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021); republished __TAXATION OF EXEMPTS ___ (2021).
Partnerships, Making “Qualified Offers,” and Conservation Easement Disputes: Analyzing Problems with the IRS’s Positions, Now and Later, ___ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2020); republished in ___ TAXES — THE TAX MAGAZINE __ (2021).
Conservation Easements and Pine Mountain: Favorable Rulings by Court of Appeals and Pending Issues JOURNAL OF TAXATION __ (2021); republished in __ JOURNAL OF REAL ESTATE TAXATION _ (2021); republished __TAXATION OF EXEMPTS ___ (2021).
Conservation Easement Settlement Initiative: More IRS Guidance, More Uncertainty, ___ TAX NOTES FEDERAL ____ (2020).
Newest IRS Action in Conservation Easement Disputes: Same Data Used
Against Different Parties, ____ JOURNAL OF TAXATION ____ (2020).
Depriving Partnerships of Access to the Independent Office of Appeals: Old and New IRS Tactics in Challenging Conservation Easements; ____ JOURNAL OF TAX PRACTICE & PROCEDURE ____ (2020); republished in ____ TAXES - THE TAX MAGAZINE ____ (2021).
Questions Remain about Conservation Easement Settlement Initiative, 168(12) TAX NOTES FEDERAL 2219 (2020); republished in 97(12) TAX NOTES STATE 1265 (2020).
Taxpayers Die but Their International Penalties Live On: Recent Cases Addressing the Broad Scope of Post-Death Assessment and Collection, __ JOURNAL OF INTERNATIONAL TAXATION ___ (2020); republished in __ JOURNAL OF TAXATION ___ (2020).
Lessons from an International Tax Dispute: Three Interrelated Cases, in Three Different Proceedings, Generating Three Separate Liabilities, ____ INTERNATIONAL TAX JOURNAL ____ (2020).
Conservation Easement Battles: The IRS Attempts to Use "Syndication Expenses" and Forms 8283 to Disallow Charitable Deductions, ____ JOURNAL OF TAX PRACTICE & PROCEDURE ____ (2020); republished in ____ TAXES - THE TAX MAGAZINE ____ (2020).
IRS Issues New Form 14457 and Instructions regarding Its Comprehensive Domestic and International Voluntary Disclosure Program: Analyzing Key Aspects, ____ INTERNATIONAL TAX JOURNAL ____ (2020).
IRS Challenges “Commercial Forestry” in Conservation Easement Disputes: Getting to the Root of the Matter, ____TAXES - THE TAX MAGAZINE ____ (2020).
Conservation Easement Disputes, Expansive Data Demands by the IRS, and Scope of the Tax Practitioner Privilege under Section 7525, ____ PRACTICAL TAX STRATEGIES ____ (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2021).
Civil Suit Emphasizes Critical Role of Notifications by Tax Matter Partners in Conservation Easement and Other Tax Disputes, JOURNAL OF TAX PRACTICE & PROCEDURE (2020).
New IRS Enforcement Campaign to Stop Tax Violations by Nonresident Aliens Renting and Selling U.S. Real Property, ____ JOURNAL OF TAXATION ____ (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2020).
Second Court Rejects ""Constructive Knowledge" Theory for Willful FBAR Penalties," ____ INTERNATIONAL TAX JOURNAL ____ (2020).
Five Obscure IRS Actions in 2020 with Serious Implications for Conservation Easement Disputes, ____ JOURNAL OF TAXATION ____ (2020); republished in ____ TAXATION OF EXEMPTS (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2020).
Conservation Easement Enforcement: IRS Quietly Eliminates Procedural Protections for Appraisers, 132(5) JOURNAL OF TAXATION 17 (2020); republished in 31(6) TAXATION OF EXEMPTS 13 (2020); and ____ JOURNAL OF REAL ESTATE TAXATION ____ (2020).
Foreign Retirement and Savings Plans, Waiver of Forms 3520 and Forms 3520-A, and Limits of Rev. Proc. 2020-17, ____ INTERNATIONAL TAX JOURNAL ____ (2020); republished in ____ TAXES - THE TAX MAGAZINE ____ (2020).
Conservation Easements, Partners, and Qualified Amended Returns? 166(3) TAX NOTES FEDERAL 373 (2020).
Recent Foreign Trust Case Establishes Penalty Limits for Form 3520 and Form 3520-A Violations, ____ INTERNATIONAL TAX JOURNAL ____ (2020); republished in ____ JOURNAL OF TAX PRACTICE & PROCEDURE ____ (2020).
Evolution of Special Rules for Claiming Disaster Losses: Analyzing Remedies for Taxpayers Who Miss Election Deadlines, 104(2) PRACTICAL TAX STRATEGIES ____ (2020).
Conservation Easements, Legitimate Risks, and Potential Issues Related to Tax Result Insurance: Identifying Realities Facing the IRS, ____ PRACTICAL TAX STRATEGIES ____ (2019); republished in 31(4) TAXATION OF EXEMPTS ____ (2020); republished in ____ JOURNAL OF REAL ESTATE TAXATION ____ (2019).
Conservation Easements, Partnerships, Risks, and Profitability: U.S. Government Takes Contradictory Positions in Tax and Securities Cases, ___ JOURNAL OF TAXATION OF FINANCIAL PRODUCTS ___ (2019).
Clarifying the Reasonable-Reliance Defense to Penalties in an E-Filing Era: An Analysis of Boyle, Haynes, Intress, and More, ___ JOURNAL OF TAXATION ___ (2020); republished in __ PRACTICE TAX STRATEGIES ___ (2020).
IRS Introduces Relief Procedures for Former U.S. Citizens: Path to Avoid the Exit Tax, Income Taxes, and Penalties Despite Past Non-Compliance, INTERNATIONAL TAX JOURNAL ___ (2019); republished in ___ TAXES — THE TAX MAGAZINE __ (2020).
Conservation Easements, Recent Mayo Clinic Case, and Expanded Defenses to IRS Attacks on “Conservation Purpose,” ___ JOURNAL OF REAL ESTATE TAXATION __ (2019); republished in ___ JOURNAL OF TAXATION ___ (2019).
Clarifying Misconceptions about Extending Assessment Periods and “Cooperating” during IRS Audits, __ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2019); republished in ___ TAXES — THE TAX MAGAZINE __ (2020).
More FBAR Penalty Losses and Lessons: The Significance of Rum and Ott, ___ INTERNATIONAL TAX JOURNAL ___ (2019).
Fee Simple Charitable Donations Instead of Conservation Easements: Case on Mining Property Undercuts IRS's Core Positions, ___ PRACTICE TAX STRATEGIES ___ (2019); republished in ___ TAXATION OF EXEMPTS ___ (2019).
Conservation Easements, "Substantially Similar" Transactions, and the Reach of Notice 2017-10, ___ JOURNAL OF REAL ESTATE TAXATION ___ (2019); republished in ___ JOURNAL OF TAXATION 23 (2019).
Flume, Boyd, and Cohen: Three Recent FBAR Cases Yielding Important New Lessons, 45(4) INTERNATIONAL TAX JOURNAL 31 (2019).
Making "Qualified Offers" in Partnership Disputes: Extreme Positions by the IRS in Conservation Easements Cases Might Backfire, ___ JOURNAL OF PASSTHROUGH ENTITIES __ (2019).
IRS Amnesty Covers More than Foreign Accounts: Analyzing the Updated Voluntary Disclosure Practice, New International Tax Withholding Procedure, and Guidelines for Late Returns by Foreign Corporations, 97(6) TAXES — THE TAX MAGAZINE 19 (2019); republished in 45(3) INTERNATIONAL TAX JOURNAL __ (2019).
Conservation Easements, Partnerships, Risks and Profitability: U.S. Government Takes Contradictory Positions in Tax and Securities Cases, 16(3) JOURNAL OF TAXATION OF FINANCIAL PRODUCTS _____(2019).
What Garrity Teaches about FBARs, Foreign Trusts, "Stacking" of International Penalties, and Simultaneously Fighting the U.S. Government on Multiple Fronts, 20(6) JOURNAL OF TAX PRACTICE AND PROCEDURE 27 (2019).
Champions Retreat: Conservation Easements, Clarifications on "Significant" Preservation, and Lessons from Issues Unaddressed by the Tax Court, ______ JOURNAL OF REAL ESTATE TAXATION _____(2019); republished in 131(1) JOURNAL OF TAXATION 23 (2019).
United States v. Horowitz: Sixth Case Analyzing Constructive Knowledge as Determinant of FBAR Penalties, 45(2) INTERNATIONAL TAX JOURNAL 23 (2019); republished in _____TAXES ---THE TAX MAGAZINE___(2019).
Pine Mountain Preserve and Conservation Easements: Victory in Disguise for Taxpayers? ______ JOURNAL OF REAL ESTATE TAXATION ____(2019); republished in 130(5) JOURNAL OF TAXATION 22 (2019).
Conservation Easements, Notice 2017-10, Injunction Action, and the Potential Reach of Return Preparer Penalties under Section 6694, 21(1) JOURNAL OF TAX PRACTICE & PROCEDURE 23 (2019).
Constructive Knowledge and FBAR Penalties: Does Merely Filing a Form 1040 Suffice to Establish “Willfulness?” 45(1) INTERNATIONAL TAX JOURNAL 35 (2019); republished in 97(5) TAXES — THE TAX MAGAZINE __ (2019).
Appellate Court Jeopardizes First Holding of Non-Willfulness in FBAR Penalty Case: Round Three of the Bedrosian Battle , 30(5) JOURNAL OF INTERNATIONAL TAXATION 37 (2019); republished in 130(4) JOURNAL OF TAXATION 20 (2019).
Courts Hold that U.S. Government Can Pursue Executors, Representatives, Fiduciaries, Beneficiaries, Distributees, and Others for FBAR Penalties Assessed Against Deceased Taxpayers, 30(3) JOURNAL OF INTERNATIONAL TAXATION ___ (2019); republished in 130(3) JOURNAL OF TAXATION 16 (2019).
Extended Delays by IRS in Processing International Voluntary Disclosure Cases : Expatriations Thwarted, Estate Taxes Imposed, and Solutions Explored, 44(6) INTERNATIONAL TAX JOURNAL 13 (2019); republished in _____ TAXES - THE TAX MAGAZINE _______ ( 2019).
Anatomy of a Worker-Classification Dispute with the IRS: Securing Section 530 Relief, Avoiding Employee Status, Shifting the Burden of Proof, Recouping Fees, and More, ___PRACTICAL TAX STRATEGIES _____(2019).
Court Bucks the Trend in Willful FBAR Penalty Cases: Merely Signing Tax Returns Does Not Establish Willfulness, 44(6) INTERNATIONAL TAX JOURNAL _____ (2018); republished in 97(1) TAXES - THE TAX MAGAZINE 23 ( 2019)
What Constitutes a "Willful" FBAR Violation? Comprehensive Guidance Based on Eight Important Cases, 129(5) JOURNAL OF TAXATION 24 (2018); republished in 29(11)JOURNAL OF INTERNATIONAL TAXATION 33 (2018).
Alarming U.S. Tax Rules and Information - Reporting Duties for Foreign Retirement Plans and Accounts: Analyzing Problems and Solutions, 129(4) JOURNAL OF TAXATION 14 (2018); republished in 29 (10) JOURNAL OF INTERNATIONAL TAXATION 27 (2018).
Court Holds that Pervasive Ignorance Is No Defense to Willful FBAR Penalties: This and Other Lessons from United States v. Garrity, 44(4) INTERNATIONAL TAX JOURNAL 51 (2018).
More IRS Guidance about Section 7345, Seriously Delinquent Tax Debts, and Passport Revocation: A Comprehensive Analysis, 20(2)JOURNAL OF TAX PRACTICE & PROCEDURE 17 (2018).
New Procedures for Late Forms 1120-F and Late-Filing Waivers: The Evolution of IRS Standards and Open Issues for Foreign Corporations, 44(3) INTERNATIONAL TAX JOURNAL 19 (2018).
Extended Assessment Periods and International Tax Enforcement: Rafizadeh v. Commissioner, Unreported Foreign Assets, and Use of FATCA Weapons , 96(6) TAXES — THE TAX MAGAZINE 35 (2018).
IRS Starts Depriving Tax Debtors of Passports in 2018: New Guidance about Section 7345 and Future Tax Court Disputes, 20(1) JOURNAL OF TAX PRACTICE & PROCEDURE 37 (2018).
The Importance of Lingering TEFRA Partnership Procedures: Exploring Who Can File Court Petitions and the Consequences for Mistakes, 19(6) JOURNAL OF TAX PRACTICE & PROCEDURE 25 (2018).
Willful FBAR Penalty Case Shows Importance of Protecting Privileged Communications: What Kelley-Hunter Adds to the Foreign Account Defense Discussion, 44(1) INTERNATIONAL TAX JOURNAL 15 (2018).
Analysis of the Reasonable Cause Defense in Non-Willful FBAR Penalty Case: Teachings from Jarnagin, 128(4) JOURNAL OF TAXATION 6 (2018); republished in JOURNAL OF INTERNATIONAL TAXATION (2018).
First Taxpayer Victory in a Willful FBAR Penalty Case: Analyzing the Significance of Bedrosian for Future Foreign Account Disputes (Part 2),” 128(3) JOURNAL OF TAXATION 14 (2018); republished in 29(3) JOURNAL OF INTERNATIONAL TAXATION __ (2018).
First Taxpayer Victory in a Willful FBAR Penalty Case: Analyzing the Significance of Bedrosian for Future Foreign Account Disputes (Part 1),” 128(2) JOURNAL OF TAXATION 12 (2018); republished in 29(3) JOURNAL OF INTERNATIONAL TAXATION 54 (2018).
IRS Sets Its Sights on Nonresident Aliens with U.S. Rental Property: New Study, Significant Violations, Compliance Initiative, and Remaining Options, 45(2) JOURNAL OF REAL ESTATE TAXATION 14 (2018).
Assessing Tax Liabilities is One Thing, Collecting Them Abroad is Another: New Case Shows International Reach of the IRS, 127(5) JOURNAL OF TAXATION 2015 (2017); republished in 34 JOURNAL OF INTERNATIONAL TAXATION 29(2) (2017).
The Importance of Lingering TEFRA Partnership Procedures: Exploring Who Can File Court Petitions and the Consequences for Mistakes, ___ JOURNAL OF TAX PRACTICE & PROCEDURE ___ (2018).
Willful FBAR Penalty Case Shows Importance of Protecting Privileged Communications: What Kelley-Hunter Adds to the Foreign Account Defense Discussion, __ INTERNATIONAL TAX JOURNAL ___ (2018).
Court Applies Reasonable Cause Defense to FBAR Setting: Early Teachings from Jarnagin, ___ JOURNAL OF TAXATION ___ (2018); republished in ____ JOURNAL OF INTERNATIONAL TAXATION __ (2018).
First Taxpayer Victory in a Willful FBAR Penalty Case: Analyzing the Significance of Bedrosian for Future Foreign Account Disputes, ___ JOURNAL OF TAXATION ___ (2018); selected for republication in ____ JOURNAL OF INTERNATIONAL TAXATION __ (2018).
Assessing Tax Liabilities is One Thing, Collecting Them Abroad is Another: New Case Shows International Reach of the IRS, 127(5) JOURNAL OF TAXATION 2015 (2017); selected for republication in ____ JOURNAL OF INTERNATIONAL TAXATION __ (2017).
Has the IRS Declared Dead the Substantial Compliance Defense for International Information Returns? Lessons from a New International Practice Unit, ___ INTERNATIONAL TAX JOURNAL ____ (2017).
Can Recent “Willful” FBAR Penalty Cases against Taxpayers Help Tax Firms Fend Off Malpractice Actions? 43(4) INTERNATIONAL TAX JOURNAL 33 (2017).
Section 911 Exclusion: Unique Election, New Case, Lessons Learned, 99(2) PRACTICAL TAX STRATEGIES 4 (2017).
Pre-Trial Win in Worker-Classification Dispute Thanks to Section 530 Does Not Trigger Automatic Fee Recovery under Section 7430, 19(2) JOURNAL OF TAX PRACTICE & PROCEDURE 21 (2017).
Flume v. Commissioner and Form 5471 Penalties for Unreported Foreign Corporations: A Glimpse at Unique Aspects of International Tax Disputes, 95(8) TAXES — THE TAX MAGAZINE 39 (2017).
IRS Deprives Tax Debtors of U.S. Passports under New Section 7345: Open Issues as Enforcement Begins in 2017, 19(1) JOURNAL OF TAX PRACTICE & PROCEDURE 27 (2017).
Unlimited Assessment-Period for Form 8938 Violations: Ruling Shows IRS’s Intent to Attack Multiple Tax Returns, 95(4) TAXES — THE TAX MAGAZINE 31 (2017).
IRS Finalizes Form 5472 Regulations for Foreign-Owned, Domestic, Disregarded Entities, 43(1) INTERNATIONAL TAX JOURNAL 13 (2017).
Government Wins Fourth Straight FBAR Penalty Case: Analyzing Bohanec and the Evolution of “Willfulness,” 126(3) JOURNAL OF TAXATION 110(2017); selected for republication in 28(8) JOURNAL OF INTERNATIONAL TAXATION 34 (2017).
Where Does the Buck Stop? Recent Case Condones Non-Filing of Forms 1065 and Schedules K-1, 18(5) JOURNAL OF TAX PRACTICE & PROCEDURE 27 (2016).
IRS Proposes Form 5472 Filing Duty for Foreign-Owned Disregarded Entities, 42(4)INTERNATIONAL TAX JOURNAL 17 (2016).
Formal Document Requests under Section 982: New Case Expands Definition of “Foreign-Based Documentation” 94(9)TAXES — THE TAX MAGAZINE 33 (2016).
Taxpayer Delivers One-Two Punch to IRS in Recent Worker-Classification Dispute: Victory under Section 530 and Fee Recoupment , 18(3)JOURNAL OF TAX PRACTICE & PROCEDURE 33(2016).
Specified Domestic Entities Must Now File Form 8938: Section 6038D, New Regulations in 2016, and Expanded Foreign Financial Asset Reporting, 42(3) INTERNATIONAL TAX JOURNAL 5 (2016).
Accidental Americans: Unanticipated U.S. Income Taxes, Ongoing Information-Reporting Duties, and Exposure to Expatriation Tax for Green Card Holders, 124(4) JOURNAL OF TAXATION 170 (2016).
Children with Foreign Accounts: Unexpected Income, Schedule B, Form 8938, and FBAR Issues, 124(3) JOURNAL OF INTERNATIONAL TAXATION 134 (2016); selected for republication in 124(3) JOURNAL OF TAXATION 134 (2016).
Form 5471: How Does New IRS Guidance Impact the “Substantially Complete” Defense? 94(4) TAXES — THE TAX MAGAZINE 39 (2016). selected for republication in 42(2) JOURNAL OF INTERNATIONAL TAXATION 33 (2016).
Canadian Retirement Plans: What Does Revenue Procedure 2014-55 Mean for U.S. Tax Deferral, Form 8891, Form 8938, and the FBAR? 41(6) INTERNATIONAL TAX JOURNAL 25-37 (2016).
Form 5472 for Certain Foreign and Domestic Corporations: New Filing Procedures, New Automated Penalties, New Abatement Standards, and More. 93(5)TAXES — THE TAX MAGAZINE 45-60 (2015).
Form 8938 and Foreign Financial Assets: A Comprehensive Analysis of the Reporting Rules after IRS Issues Final Regulations, 41(2) International Tax Journal 25-50 (2015).
Government Wins Second Willful FBAR Penalty Case: Analyzing What McBride Really Means to Taxpayers With Unreported Foreign Accounts, 118(4) Journal of Taxation 187(2013).
IRS Introduces Two Unique Tax-Compliance Remedies for U.S. Persons with Unreported Canadian Retirement Plans and Accounts, 39(1) International Tax Journal 11-20 (2013).
Must Taxpayers File “Timely” Forms 1099 to Obtain Section 530 Relief? Unexpected Answers from a Recent Worker-Classification Case, 91(4) Taxes– The Tax Magazine 55-68 (2013).
Third Time's the Charm: Government Finally Collects "Willful" FBAR Penalty in Williams Case, 117(6) Journal of Taxation 319 (2012).
The New Duty to Report Foreign Financial Assets on Form 8938: Demystifying the Complex Rules and Severe Consequences of Noncompliance, 38(3)International Tax Journal 11 (2012).
Direct Sellers Hit by IRS Worker-Classification Audits: An Analysis of the Obscure Rules, Precedent, and Strategies Applicable to These Workers, 90(8) TAXES – The Tax Magazine 45 (2012).
Limited Liability Company Members and the Passive Activity Loss Rules: IRS Issues Proposed Regulations After Multiple Court Setbacks, 15(1) Journal of Passthrough Entities 51 (2012).
Qualified Amended Returns: Case of First Impression Examines Parameters of this Powerful Taxpayer Remedy, 116(2) Journal of Taxation 96 (2012).
IRS Introduces New Settlement Program for Worker-Classification Issues: Putting the Latest Employment Tax Offer into Perspective, 90(2) TAXES – The Tax Magazine 53 (2012).
Always Say Never: Tax Court Rejects IRS's Extreme Litigation Position in Penalty Cases, 13(5) Journal of Tax Practice & Procedure 43 (2011).
Better Late Than Never: The IRS Radically Changes Aggregation Election Procedures in Passive Activity Cases, 13(5) Journal of Tax Practice & Procedure 25 (2011).
If You're On Call, You're Out of Luck: Tax Court Limits Hours Counted in Passive Activity Loss Disputes, 86(4) Practical Tax Strategies 153 (2011).
The Internal Revenue Service Giveth and the Department of Justice Taketh Away: Recent Court Opinion Jeopardizes Retroactive Administrative FBAR Relief, 114(1) Journal of Taxation 18 (2011).
IRS Granted Major Mulligan in TEFRA Partnership Case: Three Novel Rulings Enable IRS to Avoid One-FPAA-Only Restriction, 89(1) TAXES – The Tax Magazine 47-58 (2011).
District Court Rules That Where There's No Will, There's a Way to Avoid FBAR Penalties, 113(5) Journal of Taxation 293-300 (2010).
Home Sweet "Property"? Tax Court Issues Examines Gain Exclusion on Sale of Principal Residence, 113(3) Journal of Taxation 175 (2010).
When Are Hard Times Hard Enough (for the IRS)? Examining Financial Distress as Reasonable Cause for Penalty Abatement During an Economic Downturn. 88(10) TAXES – The Tax Magazine 37 (2010); selected for republication in 12(5) Journal of Tax Practice & Procedure 29 (2010).
No Returns, No Problem: Tax Court Rules in Case of First Impression that IRS Must Consider "Economic Hardship" in Pre-Levy CDP Cases. 12(1) Journal of Tax Practice & Procedure 27 (2010).
As the World Turns: Court Rebuffs Novel Spin on International Tax Filing Rules, 36(2) International Tax Journal 45-48 (2010).
Strike Three for the IRS in Passive Activity Loss Cases: Courts United in Rejecting Outdated Limited Partnership Theories, 12(5) Journal of Passthrough Entities 59-69 (2009).
Exploring the Limits of State Law in Resolving Federal Tax Disputes: Tax Court Denies the IRS's "Back Door" Approach in Alimony Case, 87(8) TAXES – The Tax Magazine 67-73 (2009).
Two More Blows to Foreign Account Holders: Tax Court Lacks FBAR Jurisdiction and Bankruptcy Offers No Relief from FBAR Penalties, 11(1) Journal of Tax Practice & Procedure 27-34 (2009).
How Much Must One Pay to Play? Recent Case Clarifies Jurisdictional Deposit Requirement in TEFRA Litigation, 11(5) Journal of Passthrough Entities 39-46 (2008).
It's in the Mail, Right? Recent Decision Emphasizes Limitations on the Mailbox Rule, The Practical Tax Lawyer 15-18 (Summer 2008).
Make a Decision Already! Recent Case Highlights How IRS Inaction Can Stymie Taxpayers Requesting Abatement, The Tax Adviser 256-258 (April 2008).
From the Cradle to the Grave: What Remains of Interest Suspension under Section 6404(g)? 10(1) Journal of Tax Practice & Procedure 41-50 (2008); selected for republication in 58(10) The Monthly Digest of Tax Articles 51-63 (2008).
There Are Some "Guaranties" in Life, But Do You Want to Be the One Making Them? Analyzing the Unique Tax Rules for Bad Debt Losses, 10(5) Corporate Business Taxation 29-34 ( 2009).
When Bygones Aren't Bygones: Exploring Solutions for U.S. Persons with Undeclared Canadian Retirement Plans and Accounts, 34(4) International Tax Journal 35-43 (2008).
Beware of the Two-Hatted Tax Matters Partner: Analyzing How Dual Roles Can Impact TEFRA Litigation, 10(6) Journal of Passthrough Entities 31-40 (2007).
Where There's a Will, There's a Delay: Do Recent Legislative Changes to the CDP Rules Solve the Perceived Problems? 85(11) TAXES – The Tax Magazine 39-44 (2007); selected for republication in 9(5) Journal of Tax Practice & Procedure 41-46 (2007).
Seeking Cost Reimbursement in Cases of First Impression: Zealous Advocacy or Pushing Your Luck? 21(3) The Practical Tax Lawyer 15-22 (2007).
Applying Old Theories in New Contexts: Interest Suspension Upheld Where Government Failed to Prove Fraud, 9(3) Journal of Tax Practice & Procedure 15-18, 47-48 (2007).
The Document Locator Number: Little-Known IRS Notation May Establish Tax Return Filing Date, 78(1) Practical Tax Strategies 4-11 (2007).
New Penalties for Undisclosed Foreign Accounts: Putting the Cart before the Horse? 8(3) Journal of Tax Practice & Procedure 29-36 (2006).
Evolution of the FBAR: Where We Were, Where We Are, and Why It Matters. 7(1) University of Houston Business & Tax Law Journal 1-41 (2006); selected for republication in 57(12) The Monthly Digest of Tax Articles 21-41 (2007).
Repatriating Subpart F Income: A Fresh Look at Electing to be Taxed as a Corporation, 38(2) Tax Notes International 173-178 (2005), 2005 Worldwide Tax Daily 70-21 (2005).
The Evolving Treatment of Qualified Foreign Dividends: Where Do We Stand Now? 16 Journal of International Taxation 28 (2005).
You Can Catch More Flies with Honey: Debunking the Theory in the Context of International Tax Enforcement, 83(2) TAXES – The Tax Magazine 29 (2005).
Only Time Will Tell: The Growing Importance of the Statute of Limitations in an Era of Sophisticated International Tax Structuring, 30(2) Brooklyn Journal of International Law 453-484 (2005); selected for republication in 57(6) The Monthly Digest of Tax Articles 1-15 (2007).
Tax Treatment of Foreign Dividends Under the JGTRRA: Further Ambiguities and Opportunities, 15(10) Journal of International Taxation 20-27 (2004).
Regulating Foreign Disregarded Entities with Proposed Form 8858: Try, Try Again, 33(7) Tax Management International Journal 412-425 (2004).
The Impact of Recent Events on Section 911: Rocking the Boat or Capsizing the Vessel? 34 Tax Notes International 285 (2004), 2004 Worldwide Tax Daily 75-12 (2004).
The Foreign Earned Income Exclusion: U.S. International Tax Policy, Political Reality, and the Need to Understand How the Two Intertwine, 37(3) Vanderbilt Journal of Transnational Law 727 (2004).
Florida Forecast: More Rain on the Offshore Parade, 15(3) Lawyer 36-37 (2004).
Reduced Tax Rates on Foreign Dividends Under the Jobs and Growth Relief Reconciliation Act: Ambiguities and Opportunities, 15(7) Journal of International Taxation 14-27 (2004).
The New Federal-State Tax Enforcement Alliance: Carrots, Sticks and Implications for Taxpayers, 13(10) Journal of Multistate Taxation and Incentives 14-23, 46 (2004).
Fight or Flight of U.S.-Based Multinational Businesses: Analyzing the Causes for, Effects of, and Solutions to the Corporate Inversion Trend, 23(3) Northwestern University Journal of International Law and Business 551-588 (2003).
Rethinking Tax-Based Export Incentives: Converting Repeated Defeats Before the WTO Into Positive Tax Policy, 39(1) University of Texas International Law Journal 111-142 (2003).
The Andean Trade Preference Act: Past Accomplishments and Present Circumstances Warrant Its Immediate Renewal and Expansion, 34(4) George Washington University International Law Review 743-788 (2003).
Privilege, Work-Product Doctrine, and Other Discovery Defenses in IRS's International Tax Enforcement, 32(4) Tax Notes International 377-396 (2003), 2003 Worldwide Tax Daily 207-14 (2003).
Reduced Tax on Foreign Dividends: A Dose of Holiday Cheer for U.S. Investors, 14(4) Lawyer 34 (2003).
Revamping the Export-Import Bank in 2002: The Impact of this Interim Solution on the United States and Latin America, 6(1) New York University Journal of Legislation and Public Policy 89-130 (2002).
The NAFTA Trucking Dispute: Pretexts for Noncompliance and Policy Justifications for U.S. Facilitation of Cross-Border Services, 11 University of Minnesota Journal of Global Trade 235-275 (2002).
Partial Revocation of the Caribbean Basin Trade Partnership Act: An Analysis of Hemispheric Injuries and Domestic Benefits, 28 University of North Carolina Journal of International Law and Commercial Regulation 101-143 (2002).
Salvaging Trade, Economic and Political Relations with Mexico in the Aftermath of the Terrorist Attacks: A Call for a Reevaluation of U.S. Policy, 20(1) Boston University International Law Journal 33-72 (2002).
Reauthorizing the Export-Import Bank Affects Trade in the Americas, 9(8) Inter-American Trade Report (2002).
The Continued Dumping and Subsidy Offset Act (Byrd Amendment): A Defeat Before the WTO May Constitute an Overall Victory for U.S. Trade, 10 Tulane University Journal of International and Comparative Law 121-155 (2002).
Trade Promotion Authority: Current Status and Potential Effects on U.S.-Latin America Trade, 9(4) Inter-American Trade Report 1-11 (2002).
U.S. Action to Freeze Assets of Terrorism: Manifest and Latent Implications for Latin America, 17(3) American University International Law Review 625-639 (2001).
The International Monetary Stability Act: Recognizing the Ripeness of this Economic Legislation to Render Benefits for the United States and Mexico, 32(3) University of Miami Inter-American Law Review 375-435 (2001).
Cross-Border Financing: The Impact of Recent Legislation on NAFTA Signatories, 15(2) Texas Transnational Law Quarterly 6-13 (2001).
Overcoming Apathetic Internationalism to Generate Hemispheric Benefits: An Analysis of and Arguments for Recent Secured Transactions Law in Mexico, 10(2) Florida State University Journal of Transnational Law & Policy 133-181 (2001).
U.S. Export Control Changes Concerning Cuba – Potential Gains for U.S. Agriculture, 8(15) Inter-American Trade Report 2139-2147 (2001).
Introduction of U.S. Currency in Ecuador: Arguments for External Participation, 16(2) Florida International Law Quarterly 12-18 (2001).
The New Mexican Insolvency Law: Imperative Judicial Modernization and Policy Justifications for U.S. Assistance, 6(1) UCLA Journal of International Law and Foreign Affairs 45-87 (2001).
Pensions in Brazil: Time for the Harvest, 3(1) Latin Insurance, 22-24 (2001).
Dollarization of Ecuador: Sound Policy Dictates U.S. Assistance to This Economic Guinea Pig of Latin America, 11(1) Indiana University International and Comparative Law Review 79-114 (2000).
Reinsurance in Brazil: The Rough Road to Privatization, 7(2) Journal of Reinsurance 1-12 (2000).
Transformation of the Costa Rican Insurance Market: Losing the Battle, Winning the War, 9(4) Global Reinsurance, 50-52 (2000).
Healthcare in Brazil: Bring Your Own Aspirin, 48(3) Health Insurance Underwriter 35-40 (2000).
Legalities vs. Realities: Privatization of the Nicaraguan Telecommunications Industry Gives New Meaning to the Phrase Caveat Emptor, 15(1) Texas Transnational Law Quarterly 7-11 (2000).
One Step Closer to Privatization? Legal Horizons (2000).
La internacionalidad de los mercados, la responsabilidad objetiva y la comercialización de productos defectuosos provenientes de Chile, 206 Universidad de Concepción (Chile) Revista de Derecho 43-73 (1999).
MERCOSUR and the Insurance Sector: At the Integration Crossroads, 2(3) Latin Insurance 24-27 (1999).
Native Forest Protection in Chile: The Inadequacies of the Recent Environmental Framework Law, 14(1) University of Oregon Journal of Environmental Law and Litigation 225-299 (1999).
El trabajo infantil en América Latina y Perú: un programa para su reducción, 29 Debate Agrario (Peru): Análisis y Alternativos 81-112 (1999).
Certificación forestal: una opción medioambiental de vanguardia para Chile, XV(4) Ambiente y Desarrollo 54-57 (1999).
Pension Reforms in Latin America, Legal Horizons 22-24 (1999).
Timber Certification: An Alternative to the Destruction of the Chilean Forests, 14(2) University of Oregon Journal of Environmental Law and Litigation 301-350 (1999).
The Lome Convention in the Next Millennium: Modification of the Trade/Aid Package, 7(3) University of Kansas Journal of Law & Public Policy 83-104 (1998).

Blog Posts

IRS ALERT: IRS Implements Employee Retention Credit Voluntary Disclosure Program
Tax Blog/Blawg, December 24, 2023
2023 BEA Filing Deadline
Tax Blog/Blawg, June 6, 2023
Must Taxpayers File “Timely” Forms 1099 to Obtain Section 530 Relief? Unexpected Answers from a Recent Worker-Classification Case
Tax Blog/Blawg, April 29, 2013
Government Wins Second Willful FBAR Penalty Case: What McBride Really Means to Taxpayers with Unreported Foreign Accounts
Tax Blog/Blawg, April 25, 2013
IRS Introduces Two Unique Remedies for U.S. Persons with Unreported Canadian Retirement Plans and Accounts
Tax Blog/Blawg, February 6, 2013
IRS Finally Collects Civil “Willful” FBAR Penalty in Williams Case – Court Introduces New Lower Standard for Penalizing Taxpayers with Unreported Foreign Accounts
Tax Blog/Blawg, December 7, 2012
Direct Sellers Hit by IRS Worker - Classification Audits
Tax Blog/Blawg, December 5, 2012
The New Duty to Report Foreign Financial Assets on Form 8938: Demystifying the Complex Rules and Severe Consequences of Noncompliance
Tax Blog/Blawg, July 15, 2012
The Parameters of Qualified Amended Returns Examined by Tax Court in Case of First Impression
Tax Blog/Blawg, March 9, 2012
LLC Members and the Passive Activity Loss Rules: IRS Issues Proposed Regulations After Multiple Court Setbacks
Tax Blog/Blawg, February 29, 2012
When Bygones Aren't Bygones: Exploring Tax Solutions for U.S. Persons with Undeclared Canadian Retirement Plans and Accounts
Tax Blog/Blawg, February 24, 2012
Settlement Program for Worker-Classification Issues: Putting the Latest Employment Tax Offer into Perspective
Tax Blog/Blawg, February 23, 2012
If You're On Call, You're Out of Luck in Passive Activity Cases
Tax Blog/Blawg, February 21, 2012
Better Late than Never: IRS Radically Changes Aggregation Election Procedures in Passive Activity Cases
Tax Blog/Blawg, February 14, 2012
Always Say Never: Does Financial Distress Create Reasonable Cause Sufficient To Abate Tax Penalties?
Tax Blog/Blawg, February 6, 2012
As the World Turns: Court Rebuffs Novel Spin on International Tax Filing Rules
Tax Blog/Blawg, March 25, 2011
Where There's No Will, There's a Way to Avoid FBAR Penalties
Tax Blog/Blawg, March 15, 2011
IRS Giveth and DOJ Taketh Away: Recent Opinion Jeopardizes Retroactive FBAR Relief
Tax Blog/Blawg, March 8, 2011

Hale E. Sheppard

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