Prose by Tax Pros

Getting audited by the IRS is bad enough, but having the IRS tell friends, colleagues, employers, clients and others about it can be worse. Unfortunately, the IRS does this on a regular basis through a process called making third party contacts (“TPCs”). Taxpayers often lack knowledge about TPCs, mandatory warnings, exceptions to general notice requirements, opportunities to supply data to the IRS to prevent TPCs, and various legal procedures for retrieving details about TPCs. This article addresses these critical points. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

Globalization is triggering more tax disputes with the IRS, and winning such clashes requires knowledge of both substantive international tax law and complicated procedures. A good example is Mattson v. United States. That case involves U.S. citizens working overseas, claims for special tax benefits for expatriates, the effect of Closing Agreements, novel interpretations of treaties, refund actions and procedural twists. Using Mattson as a starting point, this article shows how international tax and tax procedure often converge in modern battles with the IRS. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.