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Allison, Mark D.
Armitage, J. Clark
Barnes, Peter A.
Barzell, Dustin J.
Biss, Meghan R.
Black, Jonathan R.
Brenner, Jonathan S.
Burmester, Kirsten
Caplin (1916 - 2019), Mortimer M.
Carney, Leila D.
Carney, Robert T.
Child, Josiah
Crawford , Monty
Davis, Kevin M.
Drysdale (1924 - 2018), Douglas D.
Eisenstat, Benjamin Z.
Elber, Niles A.
Fournier, William D.
Goon , Michael
Hannes, Steven P.
James , Shamara R.
Jaramillo, Victor A.
Kauffman, Allegra
Kaufman, Beth Shapiro
Klimon, William M.
Kochman, Neal M.
Koski, Jeanna Rickards
Langley, Ann Weber
Laughlin, Felix B.
Leon, Amanda M.
Lewis, Patricia Gimbel
Liesemer, Jeffrey A.
Maclay, Kevin C.
Marshall, Olivia N.
Matthews, Mark E.
McMillan, Ann C.
Michel, Scott D.
Miller, Nathaniel R.
Morgan, Bryson B.
Muncey , Meghan E.
Namorato, Cono R.
O'Brien, Anne J.
O'Connor, George M.
Phillips, Todd E.
Polk, Shauna
Potter, Trevor
Raafi, Shahriar M. (Shah)
Rizek, Christopher S.
Rosenbaum, Daniel B.
Rosenbloom, H. David
Ruchelman, Charles M.
Salles, James E.
Sanderson, Matthew T.
Schafroth, Heather D.
Schick, Sharon H.
Self , Lucas H.
Sharkey, Ross R.
Skillman, Richard W.
Slocombe, Walter B.
Smiley, Stafford
Smith, Lauren G.
Stevens, Elizabeth J.
VanderMeulen, Eleanor S.
Varley, Douglas N.
Want, Sharon P.
Wehner, James P.
Wernke, Megan E.
Wiley, Melissa L.
Zendeh, Katy
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Business, Investment & Transactional Tax Alert
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International Tax Alert
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By Attorney:
Charles M. Ruchelman
Alerts
International Tax Alert
IRS "Dirty Dozen" List Includes "Potentially" Abusive Use of U.S.-Malta Tax Treaty in Pension Plans
August 17, 2021
Tax Alert
IRS Kicks Off Post-
Altera
Audit Adjustments
September 21, 2020
Tax Alert
IRS Will Continue Captive Insurance and Syndicated Conservation Easement Examinations Despite Covid-19 Pandemic
April 27, 2020
Tax Alert
Partnership Filing Relief
April 13, 2020
Tax Alert
Captive Soft Letter
March 31, 2020
Tax Alert
IRS Announces Tax Collection Easing and Payment Flexibility During COVID-19 Crisis
March 30, 2020
Tax Alert
Year-End Updates on Partnership Representatives
November 6, 2018
Tax Alert
Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets
November 6, 2017
Tax Alert
Captive Insurance Industry Should Be Aware of State Reporting Obligations for Transactions of Interest
February 10, 2017
Tax Alert
IRS Launches 13 Issue-Based Corporate Compliance Campaigns
February 3, 2017
Tax Alert
Syndicated Conservation Easement Transactions Identified as New "Listed Transactions"
January 3, 2017
Tax Alert
Congress Looks to Fix New Partnership Audit Rules
December 14, 2016
Tax Alert
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
November 3, 2016
Tax Alert
IRS Issues First Partnership Audit Regulations
August 8, 2016
Tax Alert
IRS Seeks Comments to Promulgate Regulations for New Tax Examination and Collection Regime for Partnerships and LLCs
March 18, 2016
Tax Alert
Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships
December 10, 2015
Tax Alert
New Law Changes FBAR Filing Deadline
August 10, 2015
Tax Alert
Abusive Small Captive Insurance Companies Added to IRS "Dirty Dozen Tax Scams"
February 13, 2015
Business, Investment & Transactional Tax Alert
Global Netting: Potential Opportunities for Corporate Taxpayers
April 10, 2013
Tax Alert
LB&I Commissioner Provides Guidance to Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties
July 29, 2011
Published Articles & Books
BLOG: IRS Releases Memo Concerning Access to Administrative File in TEFRA and BBA Examinations
www.PartnershipRepresentative.com
April 20, 2021
BLOG: IRS Provides Penalty Relief for New Capital Reporting Requirements
www.PartnershipRepresentative.com
January 26, 2021
Are The IRS's New Terms Worth It
Captive Review
December 22, 2020
BLOG: IRS Releases Proposed Regulations on Centralized Partnership Audit Regime
www.PartnershipRepresentative.com
November 30, 2020
BLOG: Centralized Partnership Audit Regime Website Launched by IRS
www.PartnershipRepresentative.com
September 8, 2020
BLOG: IRS Issues LB&I Memorandum
www.PartnershipRepresentative.com
April 7, 2020
BLOG: IRS Release Clarifications for Form 8082
www.PartnershipRepresentative.com
March 19, 2020
BLOG: IRS Release Draft Instructions to Form 8978
www.PartnershipRepresentative.com
February 26, 2020
BLOG: IRS Releases Interim Guidance Centralized Partnership Audit Regime
www.PartnershipRepresentative.com
November 27, 2019
BLOG: IRS Releases Interim Guidance on BBA Partnership Audit Procedures
www.PartnershipRepresentative.com
October 24, 2019
BLOG: Remember That You Must Appoint a Partnership Representative with Extended Form 1065 for the 2018 Tax Year
www.PartnershipRepresentative.com
July 25, 2019
BLOG: IRS Publishes New Form 8981 and Form 8984
www.PartnershipRepresentative.com
March 19, 2019
EXPERT ANALYSIS: Planning For Partnership Representatives In The New Year
Law360
January 4, 2019
BLOG: Tax Court Rules - Partnership Representative
www.PartnershipRepresentative.com
December 28, 2018
BLOG: IRS Publishes Draft Instructions for Form 8979, Partnership Representative Revocation, Designation, and Resignation Form
www.PartnershipRepresentative.com
December 5, 2018
Captive Insurance: State Reporting Obligations for Transactions of Interest
International Law Office
March 3, 2017
IRS Launches Issue Based Corporate Compliance Campaigns
Global Tax Weekly
February 16, 2017
Syndicated Conservation Easement Transactions Identified as New 'Listed Transactions'
International Law Office
January 27, 2017
Tax Claims - Court of Federal Claims: Jurisdiction, Practice, and Procedure
Court of Federal Claims: Jurisdiction, Practice, and Procedure
January 9, 2017
Congress Looks to Fix New Partnership Audit Rules
International Law Office
January 6, 2017
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
International Law Office
November 25, 2016
IRS Seeks Comments for New Tax Examination and Collection Regime
International Law Office
April 8, 2016
US Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships and LLCs
Family Office Elite Magazine
April 1, 2016
Congress Enacts New Tax Examination and Collection Regime for Partnerships
International Law Office
January 22, 2016
Moore
Requires 'More' Scrutiny of IRS-Imposed FBAR Penalties Under the Administrative Procedures Act
Family Office Elite Magazine
July 17, 2015
Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List
International Law Office
February 27, 2015
Enforcing Non-U.S. Tax Authority Requests for Taxpayer Information
International Law Office
March 7, 2014
Washington Tax Roundup
Washington Jewish Week
January 8, 2014
Jurisdictional Uncertainty in Trust Fund Recovery Penalty Cases
Tax Notes, p. 963
December 16, 2013
Global Netting: Potential Opportunities for Corporate Taxpayers
WTE Practical International Tax Strategies, Volume 17, Number 8
April 30, 2013
Once Again Employment Tax Compliance at the Forefront of IRS's Enforcement Agenda
Bloomberg Law Reports
June 21, 2010
Kiva Dunes and Golf Course Conservation Easements: Important Implications for Tax Deductibility of Conservation Easement Contributions
Free State Accountant
January 1, 2010
A $200,000 Penalty for a $25,000 Deduction??!!: the High Price of Failing to Disclose Listed Transactions Under Section 6707A of the Code
November 7, 2008
Conservation Easements Under Fire: A Five-Point Strategy to Defend the Deduction
Maryland Society of Accountants: The Free State Accountant
June 1, 2008