Philip Karter. Philip Karter focuses primarily on taxation debate and taxation litigation things

Philip Karter. Philip Karter focuses primarily on taxation debate and taxation litigation things

Practise Segments

Education

Emory School, B.A. 1979

School of Wisconsin School of legislation, J.D., 1982

Ny institution college of rules, LL.M. (tax), 1984

Awards

Club Admissions

Courtroom Admissions

U.S. Superior Legal

U.S. legal of is of interest for its Fourth, Seventh, Eighth and Federal Circuits

U.S. The Courtroom of Government Assertions

U.S. area trial for any east area of Pennsylvania

U.S. area courtroom towards area of Columbia

U.S. District judge for that District of Connecticut

U.S. The Courtroom of Global Business

Shape

Philip Karter specializes in taxation debate and taxation lawsuit topics. With his 37-year profession, Mr. Karter has actually litigated Federal tax covers in the usa section surfaces, the United States income tax courtroom together with the United States legal of national comments, and asserted in the United States the courtroom of is of interest in numerous circuits. Their array of test experiences, including a large number of court and non-jury covers made an effort to judgment, entails a wide variety of complex and high-profile income tax is significant, some with content of engaging problems of first opinion. Mr. Karter’s deeper experience with the tax conflict and court procedures, operating both pros and cons the federal government, in addition supplies him or her with invaluable observations for you to design and record transactions to prevent long-term taxation conflicts or, if this sort of disagreements tend to be unavoidable, to position this business when you look at the very best mild to properly stand up to IRS examination and test.

Consultant samples of income tax debate and litigation matters/issues taken care of by Mr. Karter put:

  • Dangerous takeover costs
  • Base moving or income tax lowering dealings
  • Transfer value transformations
  • Worthless inventory claims
  • Captive insurance policies arrangements
  • Profits, property and present tax valuation problem
  • Taxation and tax penalty issues regarding cryptocurrency (Bitcoin, Ethereum, etc.)
  • Concealed sales also partner/partnership recharacterizations
  • Debt-equity swaps because monetary product problem
  • Greenmail transaction
  • Foreign taxation breaks
  • Treatment taxation loans, low-income home income tax credits, and economic growth credit
  • Transition law income tax credits
  • § 162(meters) qualified performance-based pay
  • Unpaid accept investment fees under § 6672 (Rely On Account Data Recovery Fee (“TFRP”))
  • Cures as worker or separate specialist
  • § 7805(b) retroactivity of requirements and disparate remedies
  • §183 interest damages
  • Wood depletion
  • Coal excise fees
  • Mitigation of rules (§§ 1311 – 1314)
  • Res judicata and collateral estoppel
  • Interest recomputations and netting
  • IDR answers and record productions
  • IRS summon administration procedures
  • Income tax penalty troubles

Mr. Karter features taken care of many different tax debate does matter for customers which ranges from luck 500 providers to small businesses, shared endeavors and individuals that have been resolved utilizing the IRS right at the assessment degree, administrative appeals or through approach dispute solution (ADR). As well as standing for citizens overall steps of taxation audits, appeals and litigation, the man shows person citizens in the next cities:

  • Needs for Review Reconsideration
  • Offers in bargain
  • Release payment arrangements
  • Tax lien and levy secretes
  • Taxation lien subordination
  • Lineup because processes (CDP) proceeding, is attractive and income tax trial lawsuit
  • Unlawful levy statements
  • Troubles to respect levy strategies
  • Erroneous your money back practices
  • Simple partner help and equitable help under § 6015(f)
  • International financial account reporting needs, like OVDP submissions
  • Local voluntary disclosures
  • Eggshell audits
  • Citizen Endorse Tool (TAS) articles

Well before becoming a member of Chamberlain Hrdlicka in 2007, Mr. Karter got a partner at Miller & Chevalier and previously served as an endeavor attorney making use of U.S. office of Justice Tax section, just where he had been recognized aided by the division’s excellent lawyers prize.

Mr. Karter is certainly a locate range attorneys thought to be a national influence in taxation conflict and lawsuit by Chambers American and everyone appropriate 500 Litigation and Tax courses and it is the only real federal income tax controversy attorneys operating out of Pennsylvania to obtain national credit from your distinguished Chambers positions syndication .

Chambers has the benefit of positioned Chamberlain Hrdlicka among the leading tax debate law offices in america for your tenth consecutive season, which correlates with Mr. Karter’s signing up with the corporation. He’s furthermore perennially called in finest legal professionals in America®, on the list of disabled dating apps reddit lawful profession’s eldest and the majority of respectable peer-review periodicals, and thought to be “Lawyer of the season” in Tax Litigation and Controversy for Philadelphia in the 2019 model. The lawyer evaluation tool Avvo furthermore assigns Mr. Karter a 10, actually highest-ranking.

Mr .Karter has actually talked on several taxation issues before the United states club Association’s portion of tax, the taxation professionals Institute, government employees Bar connection, the fresh new York University college of guidelines, the Georgetown school rules core, The Southern national taxation Institute, the Palm seashore taxation Institute, and other county bar and pro interaction. She is currently a user associated with the Philadelphia club connections’s taxation advice.

In conjunction with their very long career in tax conflict and court, Mr. Karter has worked for years on several tax planning counts, with a particular focus on real estate investment opportunities collaborations. The Man presently works together house builders and people in Good Possibility Area (QOZ) tasks authorized by latest Inner Income Code §1400Z. Mr. Karter additionally maintains a proactive practise assisting businesses develop both § 831(a) and § 831(b) attentive insurance coverage agreements.

Significant Problems

[April 2017] Obtained “no modifications” emails (full IRS concessions) for the low-income property task developer/tax credit syndicator following your IRS conceded proposed aggregate exam modifications of $5 million for alleged disguised business by relationships for their business partners of say lower income cover income tax credits. In addition received an entire concession of IRS $one million treatment against syndicator claiming that deals of relationship passions happened to be regular money than capital gain.

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