Employee Retention Credits: Separating Fact from Fiction as IRS Disputes Get Underway
OL1341 | On Demand Course | Update | Self-Study
Description
This tax incentive has all the elements necessary to ignite a major battle: A complex law, multiple sources of administrative guidance, rules with retroactive effect, delays and oversights, reports criticizing IRS errors, large numbers of eligible taxpayers, companies advertising questionable credit claims, open assessment periods, and repeated IRS warnings of serious civil and criminal enforcement. This presentation explains the rules, common misconceptions, positions by taxpayers, attacks by the IRS, and main issues arising in the many ERC battles getting underway.
This course is part of the 2024 Tennessee Federal Tax Conference Bundle. Purchase the conference bundle here.
Credits
| Number of Credits | Type of Credits |
|---|---|
| 1.00 | Taxes |
Prices
- Member (Early Bird)
- $49.00
- Non-Member (Early Bird)
- $79.00
- Member
- $49.00
- Non-Member
- $79.00
Instructors
Hale E. Sheppard, JD, LLM
Hale E. Sheppard is a Shareholder in the Tax Dispute Section and Chair of the International Tax Section of Chamberlain Hrdlicka. He defends individual and businesses with IRS problems, particularly those involving international issues.
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 ranks among the most active tax writers in the country, publishing over 150 major articles in some of the nation's top law reviews and tax journals, including Journal of Taxation, International Tax Journal, The Tax Adviser, Journal of International Taxation, Journal of Tax Practice and Procedure, Taxes Magazine, Practical Tax Lawyer, Journal of Passthrough Entities, Tax Management International Journal, Journal of Multi-State Tax & Incentives, Tax Notes International, Practical Tax Strategies, Journal of Real Estate Taxation, Journal of Taxation of Financial Products, and Corporate Business Taxation.
Hale has participated in over 120 cases before the U.S. Tax Court, with recent rulings including Landow v. Commissioner, T.C. Memo 2011-177 (Tax Court case regarding employee stock ownership plans and taxpayer rights in cases of involuntary conversations), Virginia Historic Tax Credit Fund v. Commissioner, T.C. Memo 2009-295, rev'd 639 F.3d 129 (case of first impression regarding federal tax treatment of state tax-credit partnerships), Topping v. Commissioner, T.C. Memo 2007-92 (hobby loss case in which the Tax Court ruled in favor of the taxpayer on all major issues), Vines v. Commissioner, 126 T.C. 279 (case of first impression involving use of mark-to-market accounting by securities traders).
Hale has also obtained over 20 favorable Private Letter Rulings for clients from the IRS National Office on assorted procedural, tax, and international issues.
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