• Prose by Tax Pros - Another Article by Hale E. Sheppard

  • By: Hale E. Sheppard
  • Podcast

Prose by Tax Pros - Another Article by Hale E. Sheppard

By: Hale E. Sheppard
  • Summary

  • Most tax “articles” published these days are just summaries, not substance. Their lack of context, critical thought, and practical solutions often leaves readers with more questions than answers. Breaking this trend, the articles accessible here provide rare insight about complicated tax issues, making them both interesting and understandable. Please listen in for a series of articles, written by an attorney dedicated to tax disputes and international tax, previously published in major journals, and read by professionals.
    Hale E. Sheppard
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Episodes
  • A Look at the Second ERC Voluntary Disclosure Program
    Oct 30 2024

    Congress introduced the Employee Retention Credit (“ERC”) more than four years ago, but serious enforcement actions are just now getting underway. The IRS, as one part of its comprehensive strategy, has been implementing a multi-step plan designed to convince taxpayers to willingly return ERC payments that they did not deserve in the first place. This article, the latest in a series, analyzes the evolution of ERC benefits by Congress, the no-win situation facing the IRS initially, and some of the steps taken that the IRS has taken thus far to reduce the number of taxpayers it must pursue, including the introduction of its second voluntary disclosure program.

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    33 mins
  • Altered, Backdated and Inconsistent Documents Aren’t Enough for Fraud
    Oct 23 2024

    Taxpayers who engage in tax fraud face serious consequences, including steep penalties, endless assessment-periods, prolonged trials, reputational damage, and more. Mere allegations of fraud by the IRS can trigger these types of damaging outcomes. Cynics often argue that this is precisely the reason the IRS sometimes claims that fraud occurred in the first place. Fortunately for taxpayers, while alleging fraud is relatively easy, proving it can be hard for the IRS. Two recent Tax Court cases, analyzed in this article, demonstrate this reality.

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    31 mins
  • The Latest on Foreign Trusts: Enforcement Actions, Relief Measures, New Cases, Proposed Regulations, and More
    Oct 10 2024

    Things constantly evolve when it comes to U.S. tax and information-reporting duties for foreign trusts. A major challenge for taxpayers is keeping up with all the changes because they derive from different sources, in different contexts, at different times. In an effort to clarify and update matters, this article offers a summary of foreign trust rules, followed by a chronological review of the latest enforcement actions, relief measures, cases, regulations, and more.

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    30 mins

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