Each FBAR case is unique, teaching valuable lessons about the evolving definition of “willfulness,” key procedural issues, etc. This article centers on two recent cases, Rum and Ott, and what they add to the dialogue on FBAR penalty defense.

This recording explains the evolving attacks against conservation easement deductions by the IRS, describes the scope and limitations of the Section 7525 federally authorized tax practitioner privilege, and identifies the theories recently raised by the IRS in its effort to gather all potentially pertinent data, including communications with accountants.

Hale E. Sheppard examines the conservation easement donation process and potential flaws with the IRS’s stringent position on “commercial forestry.”

This article identifies the U.S. tax and information-reporting duties triggered by holding foreign assets, explains several different disclosure programs currently offered by the IRS, reviews the original guidance from the IRS upon announcing the UVDP back in 2018, and analyzes important information added by the IRS in 2020.

This article provides an overview of the easement donation process, describes many of the well-known IRS enforcement techniques, and analyzes

the significance of the more obscure steps, largely procedural in nature, taken by the IRS lately.

Hale E. Sheppard's article explains the conservation easement donation process, main stages of a partnership tax dispute, specific data sharing duties imposed on a TMP, recent challenges by the IRS, and allegations by the partners.

Hale E. Sheppard's article explains the conservation easement donation process, main stages of a partnership tax dispute, specific data sharing duties imposed on a TMP, recent challenges by the IRS, and allegations by the partners.