IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler BrodyPublished: R&H Letter to Clients and Friends, July 3, 2012
IRS Modifies 2011 Offshore Voluntary Disclosure Initiative to Reduce Penalties for Certain Participants and Permit Extensions
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David RozenPublished: R&H Letter to Clients and Friends, June 22, 2011
IRS Further Extends Deadline for 2009 and Prior FBARs Required to be Filed by U.S. Persons With Signature Authority but No Financial Interest in Foreign Accounts
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David RozenPublished: R&H Letter to Clients and Friends, June 21, 2011
Series LLC -- Is It Finally Usable?
by Howard J. Levine, Daniel W. StahlPublished: New York University -- 69th Institute on Federal Taxation, May 01, 2011
Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David RozenPublished: R&H Letter to Clients and Friends, April 06, 2011
Certain Taxpayers May Avoid Penalties If They File Delinquent Information Returns Relating to Foreign Accounts, Foreign Entities, and Foreign Gifts
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David RozenPublished: R&H Letter to Clients and Friends, March 02, 2011
IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David RozenPublished: R&H Letter to Clients & Friends, February 09, 2011
Series LLC -- Is It Finally Usable?
by Howard J. Levine, Daniel W. StahlPublished: BNA Tax Management Real Estate Journal, November 03, 2010
IRS Issues Relief from FBAR Filing Obligations for Three Groups
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David RozenPublished: R&H Letter to Clients & Friends, March 03, 2010
IRS Extends Deadline For Voluntary Disclosure Program
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David RozenPublished: R&H Letter to Clients and Friends, September 24, 2009
Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David RozenPublished: R&H Letter to Clients and Friends, July 22, 2009
Proposed Regulations 'Clarifying' the Technical Taxpayer Rule Don't Pass the Giggle Test
by Howard J. Levine, Michael J. MillerPublished: International Tax Journal, February 01, 2007
A (Necessary) View of the Re-Proposed Prop. Regs. §1.468B-6 on Interest Earned from §1031 Exchange Accounts
by Howard J. LevinePublished: Tax Management Memorandum, July 24, 2006
Recent Developments Affecting Like-Kind Exchanges Under §1031
by Howard J. LevinePublished: Tax Management Memorandum, March 20, 2006
Finally, IRS Issues Ruling Under Rev. Proc. 2002-22 Involving Multi-Tenant Building with Blanket Mortgage
by Howard J. LevinePublished: Tax Management Memorandum, March 07, 2005
Avoiding U.S. Tax On Foreign Sales To U.S. Customers
by Howard J. Levine, Michael J. MillerPublished: The Metropolitan Corporate Counsel, October 01, 2004
FSA 200220005: IRS Again Attempts to Void Contract Manufacturing Arrangements Under Subpart F
by Howard J. Levine, Peter A. GlicklichPublished: Taxation of Global Transactions, December 01, 2002
Electronic Arts: Taxpayers Appear to Win a Battle on the Subpart F Contract Manufacturing Front
by Howard J. Levine, Peter A. GlicklichPublished: Taxation of Global Transactions, August 15, 2002
Undivided Fractional Interests and Sec. 1031: Revenue Procedure Brings Clarification But With Some Confusion
by Howard J. LevinePublished: Tax Management Memorandum, August 12, 2002
IRS Wields the Two-Edged Sword of Code Sec. 956
by Howard J. Levine, Peter A. GlicklichPublished: Taxation of Global Transactions, April 15, 2002
'Textron' Makes for Mischief: Tax Court Opens a Pandora's Box
by Howard J. Levine, Peter A. GlicklichPublished: Taxation of Global Transactions, January 15, 2002
Accessing the Manufacturing Exception to Subpart F Through Contract Manufacturing Arrangements
by Howard J. Levine, Michael J. Miller, Peter A. GlicklichPublished: Journal of Taxation of Global Transactions, December 01, 2001
The IRS's Long Awaited Guidance on Parking Arrangements to Facilitate Like-Kind Exchanges
by Howard J. LevinePublished: The Journal of Real Estate Taxation, November 15, 2000
New Safe Harbor for Reverse Like-Kind Exchanges
by Howard J. Levine, Lary S. Wolf, Joseph Lipari, Ezra DyckmanPublished: R & H Letter to Clients & Friends, September 29, 2000
When Does E-Commerce Result in a Permanent Establishment? The OECD's Initial Response
by Howard J. Levine, David A. WeintraubPublished: Tax Management International Journal, April 14, 2000
Tax and Reporting Rules for Escrows and Trusts Used in Deferred Like-Kind Exchanges
by Howard J. Levine, David A. WeintraubPublished: Journal of Taxation, June 15, 1999
Two-Member LLC Can Be Disregarded in 1031 Exchange Where One Member Has No Economic Interest
by Howard J. Levine, David A. WeintraubPublished: Journal of Taxation, March 01, 1999
Electronic Commerce: Taxation of Services Provided via the Internet
by Sanford H. Goldberg, Howard J. Levine, Ellen Seiler Brody, Peter A. GlicklichPublished: R & H Newsletter -- Tax Insights, October 01, 1997
Electronic Services: Suggesting a Man-Machine Distinction
by Howard J. Levine, Sanford H. Goldberg, Ellen Seiler Brody, Peter A. GlicklichPublished: Journal of Taxation, August 15, 1997
Internet Sales Pose International Tax Challenges
by Sanford H. Goldberg, Howard J. Levine, Peter A. GlicklichPublished: Journal of Taxation, June 01, 1996
Howard J. Levine, for more than 30 years, has concentrated in the taxation of like-kind exchanges, international activities, controversy and litigation, and representation before the IRS National Office and Treasury Department. Nationally known as an authority on tax-deferred exchanges, he concentrates on real estate, personal property and multi-asset exchanges, and is author of the BNA Tax Management Portfolio: Tax-free Exchanges Under Section 1031. In his international activities, he works with public and private companies in biotech, electronics, computers, pharmaceuticals, transportation, autos, equipment and apparel manufacturing, entertainment, and intercompany pricing, and with families concerning their international investments. He also co-authored the BNA Tax Management Portfolio: Income Tax Treaties - The Limitation on Benefits Article. A former Assistant Branch Chief in the Litigation Division at the IRS National Office, he has represented a broad spectrum of domestic and foreign clients in tax audits, appellate proceedings and in the U.S. Tax Court. In addition to tax audits and litigation, he represents clients before the Treasury Department and the National Office of the IRS. He has been Adjunct Professor in the LL.M. (Taxation) Programs at Georgetown Law School and George Washington University. He is on the Advisory Boards of the Journal of Real Estate Taxation, the Tax Management International Journal, and The Journal of Global Transactions (CCH). A former chairman of the Sales, Exchanges & Basis Committee of the ABA Tax Section and its Subcommittee on Like-Kind Exchanges, he has also co-chaired subcommittees on U.S. Activities of Foreigners and Tax Treaties of the ABA Tax Section. He is a member of the International Fiscal Association and the International Tax Planning Association.
He received a B.A. from Hunter College, his J.D. cum laude from SUNY at Buffalo, and LL.M. (Taxation) from Georgetown.
