Exercise Cities
Studies
Emory University, B.A. 1979
School of WI Faculty of guidelines, J.D., 1982
Ny University college of rule, LL.M. (tax), 1984
Respects
Pub Admissions
Court Admissions
U.S. Supreme Court
U.S. Court of speaks towards next, Seventh, Eighth and Federal Circuits
U.S. Courtroom of National Statements
U.S. section legal when it comes to east region of Pennsylvania
U.S. region judge for all the region of Columbia
U.S. region trial when it comes to section of Ct
U.S. Trial of Foreign Business
Visibility
Philip Karter focuses on tax controversy and taxation court matters. In the 37-year job, Mr. Karter features litigated government income tax situations in the usa area surfaces, the usa income tax courtroom and the United States Court of Federal boasts, and asserted in the United States the courtroom of Appeals in numerous circuits. His or her range of trial event, which include a lot of jury and non-jury situations tried to judgment, includes numerous types of sophisticated and high-profile income tax things, some with content of included problems of initial impression. Mr. Karter’s deeper experience with the taxation conflict and court procedure, using both pros and cons the federal government, furthermore supplies your with useful observations approach form and document business in order to avoid upcoming taxation differences or, if these types of conflicts tend to be expected, to put such business through the finest light to properly stand up to IRS examination and test.
Associate examples of income tax conflict and litigation matters/issues worked by Mr. Karter feature:
- Dangerous takeover costs
- Basis repositioning along with other income tax lowering business
- Transfer discount adjustments
- Useless regular failures
- Captive insurance policies agreements
- Revenues, home and souvenir income tax price troubles
- Income tax and tax punishment problems concerning cryptocurrency (Bitcoin, Ethereum, etc.)
- Concealed earnings because partner/partnership recharacterizations
- Debt-equity swaps and various financial products problem
- Greenmail transaction
- Foreign income tax loans
- Rehabilitation tax loans, low income houses tax loans, and monetary growth credit
- Move regulation tax credits
- § 162(meter) expert performance-based payment
- Outstanding accept fund taxes under § 6672 (Put Your Trust In Investment Data Recovery Fee („TFRP“))
- Process as staff or unbiased professional
- § 7805(b) retroactivity of legislation and disparate medication
- §183 craft failures
- Timber exhaustion
- Coal excise duty
- Minimization of limitations (§§ 1311 – 1314)
- Res judicata and guarantee estoppel
- Curiosity recomputations and netting
- IDR feedback and report production
- IRS summons enforcement procedures
- Income tax penalty problem
Mr. Karter possesses taken care of countless some other income tax debate does matter for clients including luck 500 corporations to small business, combined projects and folks that have been decided utilizing the IRS on test level, administrative is attractive or through alternate question solution (ADR). As well as presenting citizens to all levels of taxation audits, is attractive and court, they represents specific individuals for the subsequent areas:
- Demands for Audit Reconsideration
- Grants in bargain
- Installment fee agreements
- Tax lien and levy produces
- Tax lien dependence
- Choice Due procedure (CDP) proceedings, appeals and taxation trial lawsuit
- Unlawful levy assertions
- Troubles to honour levy actions
- Erroneous reimbursement measures
- Harmless wife therapy and fair help under § 6015(f)
- Overseas financial account revealing requirement, such as OVDP distribution
- Home-based voluntary disclosures
- Eggshell audits
- Citizen Advocate Solution (TAS) articles
Well before becoming a member of Chamberlain Hrdlicka in 2007, Mr. Karter was actually somebody at Miller & Chevalier and formerly supported as a trial lawyer because of the U.S. Department of Justice taxation Division, exactly where he was honored employing the division’s excellent lawyers honor.
Mr. Karter also is one among a choose range attorneys seen as a nationwide authority in tax debate and court by Chambers American and so the mankind law 500 lawsuit and income tax instructions and it’s the only real national taxation debate attorney within Pennsylvania to get nationwide identification through the exclusive Chambers rank publication .
Chambers has the benefit of ranked Chamberlain Hrdlicka as the greatest tax controversy law offices in the United States for any 10th straight yr, which correlates with Mr. Karter’s becoming a member of the firm. He or she is furthermore perennially known as in the Top Lawyers in America®, among the many authorized profession’s earliest and a lot of respectable peer-review periodicals, and thought to be “Lawyer of the season” in income tax lawsuit and atheist dating online conflict for Philadelphia inside 2019 release. The attorney rating tool Avvo furthermore assigns Mr. Karter a 10, it is highest-ranking.
Mr .Karter possesses talked on an assortment of income tax dilemmas until the American pub relation’s area of Taxation, the Tax managers Institute, the Federal Bar connection, the New York college college of legislation, the Georgetown University rules heart, The south Federal income tax Institute, the hand Beach taxation Institute, as well as other county bar and expert interaction. He can be at this time a user of Philadelphia pub connection’s taxation advice.
On top of his own long profession in tax conflict and lawsuit, Mr. Karter did for quite a while on many tax preparing counts, with a specific focus on real estate investment opportunities collaborations. He presently works with real property manufacturers and investors in Good Prospects Region (QOZ) work authorized by unique Inside Profits Rule §1400Z. Mr. Karter furthermore maintains an energetic application assisting corporations create both § 831(a) and § 831(b) attentive insurance premiums arrangements.
Noticeable Situations
[April 2017] Obtained “no correction” mail (full IRS concessions) for an essential low-income property visualize developer/tax assets syndicator as soon as the IRS conceded suggested multiple review configurations of $5 million for so-called cloaked profits by relationships to the business partners of status lower income homes tax credits. Also received one concession of IRS $a million modification against syndicator declaring that marketing of relationship needs were ordinary income other than resources obtain.