Chamberlain Hrdlicka

International Tax Controversy & Litigation Tax Planning & Business Transactions International Tax Tax

Shareholder

Hale Sheppard is a partner in the Tax Controversy & Litigation Section and Chair of the International Tax Section.  He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues. Hale's practice focuses on the following:

Overview of Practice Areas Tax audits Tax appeals  Tax Court litigation Tax refund claims and litigation Tax collection defense Penalty abatement requests Private letter ruling requests Domestic Tax Matters Conservation easement disputes  Fee simple property charitable donation disputes Captive insurance disputes Virtual currency disputes Opportunity zone disputes Section 199A deduction disputes Tax shelter "promoter" disputes (Section 6700) Return preparer penalty disputes (Section 6694) Office of Professional Responsibility disputes Listed transaction disputes (Form 8886) Reportable transaction disputes (Form 8886) Material advisor disputes (Form 8918) Federal tax credits and other disputes Worker-classification disputes:  employee vs. independent contractor Passive activity loss disputes  Reasonable compensation disputes Trust fund recovery penalty disputes  Hobby loss disputes  Bad debt loss disputes  International Tax Matters  Repatriation / Transition Tax under Section 965 Base Erosion and Anti-Abuse Tax (BEAT) Offshore Voluntary Disclosure Program (OVDP) Streamline Domestic Offshore Procedure (SDOP) Streamline Foreign Offshore Procedure (SFOP) Delinquent International Information Return Submissions Procedure (DIIRSP) Delinquent FBAR Submissions Procedure (DFSP) Foreign account reporting (Form TD F 90-22.1, FinCEN Form 114, FBAR) Foreign account tax compliance act (FATCA) Foreign asset reporting (Form 8938) Controlled foreign corporations (Form 5471) Foreign-owned U.S. corporations (Form 5472) Foreign corporations with U.S. business (Form 1120F) Passive foreign investment company (Form 8621) Foreign partnerships (Form 8865) Foreign trusts (Form 3520 and Form 3520A) Foreign disregarded entities and foreign branches (Form 8858) Transfers to foreign entities (Form 926) Non-resident alien returns (Form 1040NR) Treaty-based tax return positions (Form 8833) Closer connection exception under treaties (Form 8840) Expatriation "exit" tax issues (Form 8854) Foreign earned income exclusion (Form 2555) Foreign tax credits (Form 1116) Check-the-box foreign entity classification elections (Form 8832) International withholding (Forms 1042, 8804, 8805, W-8BEN, etc.) Foreign investment in real property tax act (FIRPTA) Passport denial or revocation disputes (Section 7345)

University of Kansas, B.S., with distinction

University of Kansas, M.A., with honors

University of Kansas, J.D.

Universidad de Chile, LL.M., with highest distinction

University of Florida, LL.M.T., graduate tax scholar