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 Bloomberg Tax Portfolio (formerly 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.
Education
- Georgetown University School of Law, LL.M. (Taxation)
- The State University of New York at Buffalo Law School, J.D., cum laude
- Hunter College, B.A.
Admissions
- New York
- District of Columbia
News & Insights
- July 3, 2012
- Publications
- June 22, 2011
- Publications
- June 21, 2011
- Publications
- May 01, 2011
- Publications
Series LLC — Is It Finally Usable?
- Howard J. Levine, Daniel W. Stahl
- New York University -- 69th Institute on Federal Taxation
- April 06, 2011
- Publications
Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011
- Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
- R&H Letter to Clients and Friends
- March 02, 2011
- Publications
- February 09, 2011
- Publications
IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline
- Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
- R&H Letter to Clients & Friends
- November 03, 2010
- Publications
Series LLC — Is It Finally Usable?
- Howard J. Levine, Daniel W. Stahl
- BNA Tax Management Real Estate Journal
- March 03, 2010
- Publications
IRS Issues Relief from FBAR Filing Obligations for Three Groups
- Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
- R&H Letter to Clients & Friends
- September 24, 2009
- Publications
IRS Extends Deadline For Voluntary Disclosure Program
- Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
- R&H Letter to Clients and Friends
- July 22, 2009
- Publications
Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program
- Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
- R&H Letter to Clients and Friends
- February 01, 2007
- Publications
- July 24, 2006
- Publications
- March 20, 2006
- Publications
Recent Developments Affecting Like-Kind Exchanges Under §1031
- Howard J. Levine
- Tax Management Memorandum
- March 07, 2005
- Publications
- October 01, 2004
- Publications
Avoiding U.S. Tax On Foreign Sales To U.S. Customers
- Howard J. Levine, Michael J. Miller
- The Metropolitan Corporate Counsel
- December 01, 2002
- Publications
FSA 200220005: IRS Again Attempts to Void Contract Manufacturing Arrangements Under Subpart F
- Howard J. Levine, Peter A. Glicklich
- Taxation of Global Transactions
- August 15, 2002
- Publications
Electronic Arts: Taxpayers Appear to Win a Battle on the Subpart F Contract Manufacturing Front
- Howard J. Levine, Peter A. Glicklich
- Taxation of Global Transactions
- August 12, 2002
- Publications
- April 15, 2002
- Publications
IRS Wields the Two-Edged Sword of Code Sec. 956
- Howard J. Levine, Peter A. Glicklich
- Taxation of Global Transactions
- January 15, 2002
- Publications
‘Textron’ Makes for Mischief: Tax Court Opens a Pandora’s Box
- Howard J. Levine, Peter A. Glicklich
- Taxation of Global Transactions
- December 01, 2001
- Publications
Accessing the Manufacturing Exception to Subpart F Through Contract Manufacturing Arrangements
- Howard J. Levine, Michael J. Miller, Peter A. Glicklich
- Journal of Taxation of Global Transactions
- November 15, 2000
- Publications
The IRS’s Long Awaited Guidance on Parking Arrangements to Facilitate Like-Kind Exchanges
- Howard J. Levine
- The Journal of Real Estate Taxation
- September 29, 2000
- Publications
New Safe Harbor for Reverse Like-Kind Exchanges
- Howard J. Levine, Lary S. Wolf, Joseph Lipari, Ezra Dyckman
- R & H Letter to Clients & Friends
- April 14, 2000
- Publications
When Does E-Commerce Result in a Permanent Establishment? The OECD’s Initial Response
- Howard J. Levine
- Tax Management International Journal