Prose by Tax Pros

  The IRS normally must identify non-compliance within a short period, which can be tricky if the relevant matters occurred abroad. Taxpayers who have failed to report worldwide income and assets, either accidentally or on purpose, hope that the proverbial clock runs out before the IRS takes action. This sometimes happens in domestic cases, but much less often in the international context. This article, using several recent Tax Court cases as a springboard, examines three tools at the IRS’s disposal for expanding assessment-periods against taxpayers with international violations. 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 yearn for certainty, as they need it to make intelligent decisions about tax-related issues. Unfortunately, doubt has arisen in connection with Section 179D, a provision that incentivizes taxpayers to make commercial buildings more energy efficient. The unsettled state of affairs can be attributed to attempts by the IRS to disregard its longstanding guidance directly on point. This article provides an overview of Section 179D, identifies the related Compliance Campaign, explains the aggressive position recently taken by the IRS about allocation of Section 179D deductions, and analyzes a list of authorities countering the IRS’s position. 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.