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.

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 Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
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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 Rozen
Published: R&H Letter to Clients and Friends, June 22, 2011
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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 Rozen
Published: R&H Letter to Clients and Friends, June 21, 2011
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Series LLC -- Is It Finally Usable?

by Howard J. Levine, Daniel W. Stahl
Published: New York University -- 69th Institute on Federal Taxation, May 01, 2011
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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 Rozen
Published: R&H Letter to Clients and Friends, April 06, 2011
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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 Rozen
Published: R&H Letter to Clients and Friends, March 02, 2011
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IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, February 09, 2011
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Series LLC -- Is It Finally Usable?

by Howard J. Levine, Daniel W. Stahl
Published: BNA Tax Management Real Estate Journal, November 03, 2010
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IRS Issues Relief from FBAR Filing Obligations for Three Groups

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
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IRS Extends Deadline For Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
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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 Rozen
Published: R&H Letter to Clients and Friends, July 22, 2009
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Proposed Regulations 'Clarifying' the Technical Taxpayer Rule Don't Pass the Giggle Test

by Howard J. Levine, Michael J. Miller
Published: International Tax Journal, February 01, 2007
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A (Necessary) View of the Re-Proposed Prop. Regs. §1.468B-6 on Interest Earned from §1031 Exchange Accounts

by Howard J. Levine
Published: Tax Management Memorandum, July 24, 2006
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Recent Developments Affecting Like-Kind Exchanges Under §1031

by Howard J. Levine
Published: Tax Management Memorandum, March 20, 2006
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Finally, IRS Issues Ruling Under Rev. Proc. 2002-22 Involving Multi-Tenant Building with Blanket Mortgage

by Howard J. Levine
Published: Tax Management Memorandum, March 07, 2005
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Avoiding U.S. Tax On Foreign Sales To U.S. Customers

by Howard J. Levine, Michael J. Miller
Published: The Metropolitan Corporate Counsel, October 01, 2004
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FSA 200220005: IRS Again Attempts to Void Contract Manufacturing Arrangements Under Subpart F

by Howard J. Levine, Peter A. Glicklich
Published: Taxation of Global Transactions, December 01, 2002
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Electronic Arts: Taxpayers Appear to Win a Battle on the Subpart F Contract Manufacturing Front

by Howard J. Levine, Peter A. Glicklich
Published: Taxation of Global Transactions, August 15, 2002

Undivided Fractional Interests and Sec. 1031: Revenue Procedure Brings Clarification But With Some Confusion

by Howard J. Levine
Published: Tax Management Memorandum, August 12, 2002

IRS Wields the Two-Edged Sword of Code Sec. 956

by Howard J. Levine, Peter A. Glicklich
Published: Taxation of Global Transactions, April 15, 2002

'Textron' Makes for Mischief: Tax Court Opens a Pandora's Box

by Howard J. Levine, Peter A. Glicklich
Published: 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. Glicklich
Published: 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. Levine
Published: 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 Dyckman
Published: 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
Published: 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
Published: 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
Published: 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. Glicklich
Published: 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. Glicklich
Published: Journal of Taxation, August 15, 1997

Internet Sales Pose International Tax Challenges

by Sanford H. Goldberg, Howard J. Levine, Peter A. Glicklich
Published: Journal of Taxation, June 01, 1996