Prose by Tax Pros

The IRS conducts large numbers of audits, the period to complete them is limited, and tax issues are becoming more complex every year. The result is that some Revenue Agents employ aggressive tactics to gather data and prepare reports. One example is issuing Summonses to third parties (i.e., somebody other than the taxpayer under audit) seeking data without first granting the taxpayer a chance to personally provide it. This article focuses on three recent items that might change the IRS’s current practice, including an amendment to Section 7602, a case of first impression in the Court of Appeals, and a recent court decision strongly criticizing inappropriate third party contacts. 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.

Taxpayers dislike paying taxes once, and they absolutely detest paying them twice. The good news is that U.S. individuals working and/or investing abroad can often mitigate “double taxation” thanks to a few mechanisms, including foreign tax credits and bilateral tax treaties. Qualifying for these benefits can be tricky, of course. One controversial issue has been whether U.S. individuals can use foreign tax credits to offset net investment income taxes. A recent Tax Court case, Toulouse v. Commissioner, partially resolves that question, while expressly leaving open the possibility of different outcomes. 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.