About Prose by Tax Pros - Another Article by Hale E. Sheppard
Most tax “articles” published these days are just summaries, not substance. Their lack of context, critical thought, and practical solutions often leaves readers with more questions than answers. Breaking this trend, the articles accessible here provide rare insight about complicated tax issues, making them both interesting and understandable. Please listen in for a series of articles, written by an attorney dedicated to tax disputes and international tax, previously published in major journals, and read by professionals.
Surprising FBAR Cases: A Mixed Bag for Taxpayers Facing Foreign Account Penalties
Tax attorney Hale E. Sheppard breaks down surprising FBAR cases that challenge traditional notions of tax penalties, revealing key takeaways for navigating foreign account audits and IRS enforcement.
19 Nov 2024
Five New Events Affecting Employee Retention Credit Disputes
Battles over Employee Retention Credit (“ERC”) claims are turning more serious now, with many audits, administrative appeals, and cases getting underway. Taxpayers hoping to prevail against the IRS or Department of Justice need to have a deep understanding of legislative, substantive, procedural, and strategic ERC issues. Understandably, loads of taxpayers are having trouble keeping up with evolving matters in the ERC world. This article, the latest in a long series, discusses five new items that might have escaped the attention of taxpayers.
13 Nov 2024
Exploring Recent Cases and IRS Guidance on Unique International Disclosure Duties for Dual Residents
Complying with international information-reporting duties is difficult; the rules are complex, dense, and obscure. Things get even more complicated when it comes to people who are residents, for tax purposes, of both the United States and another country. These so-called “dual residents” have special disclosure rules, the violation of which can trigger taxes, penalties, extended assessment periods, and more. This article explores information-reporting obligations, traditional IRS enforcement actions, and recent cases and IRS guidance featuring contradictory rulings involving dual residents.
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