Prix Fixe: Foreign Gifts and Foreign Trusts: Taxpayers Still Seeking Guidance after Two Government Concessions WEBINAR
Overview
Taxpayers have been seeking clarity on critical foreign gift and trust issues, from the IRS and the courts, for a long time. This has not occurred, largely because the government has conceded the relevant cases before litigation took place. Such pre-trial surrender by the government is positive for the one taxpayer involved in the dispute, but negative for others who desire broader guidance, strong rulings, judicial precedent on which all taxpayers can rely. This presentation compares the main obligations stemming from foreign gifts and trusts, identifies several recent events in these areas, and analyzes two new cases in which key issues affecting many taxpayers were raised, but not resolved.
Highlights
Clarity on critical foreign gift and trust issues.
Prerequisites
None.
Designed For
CPAs and other tax professionals.
Objectives
This presentation compares the main obligations stemming from foreign gifts and trusts, identifies several recent events in these areas, and analyzes two new cases in which key issues affecting many taxpayers were raised, but not resolved.
Preparation
None.
Notice
None.
Leader(s):
Leader Bios
Hale Sheppard
Hale E. Sheppard (B.S., M.A., J.D., LL.M. and LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka in Atlanta. Hale defends individuals and businesses during tax audits, appeals, and litigation. He has participated in over 250 cases with the Tax Court and obtained dozens of positive Private Letter Rulings for clients. Hale holds five college degrees. At the University of Kansas, he earned a B.S., with distinction, M.A., with honors, and J.D. He later received an LL.M. degree in international law, with highest distinction, from the University of Chile. Finally, he obtained an LL.M. degree in tax from the University of Florida, where he was a graduate tax scholar. During his studies, Hale served as a graduate editor of the Florida Tax Review and member of the Kansas Journal of Law & Public Policy. Hale has been recognized as a leader in tax litigation for many years by Chambers USA, Legal 500, and other respected organizations, and was inducted into the American College of Tax Counsel. Hale ranks among the most active tax writers in the country, publishing more than 260 articles in top tax journals and law reviews, both in the United States and abroad. He has held leadership positions in many professional organizations, including as editor of national publications and President of the Tax Section of the Georgia Bar.
Non-Member Price $60.00
Member Price $40.00