Prose by Tax Pros

Section 7345 authorizes the IRS, with assistance from the State Department, to deprive individuals with serious tax debts of their passports. Congress passed the law in 2015, the IRS began enforcing it in 2018, and the courts started issuing decisions in 2020. In short, the issues concerning passport deprivation as a tool for tax collection are new and quickly evolving. This article does the “heavy lifting” for readers by gathering, organizing and analyzing all major sources available thus far about the implementation of Section 7345. 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.

U.S. taxpayers living, investing or doing business abroad often form corporations in the local country for legitimate reasons. The problem is not establishing the corporations, but rather maintaining full compliance with the IRS thereafter. This article explains Form 5471 filing duties, stringent standards applied by the IRS and courts, obscure manners in which Form 5471 violations extend assessment-periods, places where taxpayers can and cannot dispute penalties, and a recent Tax Court case, Kelly v. Commissioner, which features several of the key issues. 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.