TAXLITIGATOR Blog

STEVEN TOSCHER to Speak at Upcoming Florida Tax Institute

We are pleased to announce that Steven Toscher will be speaking at the upcoming Florida Tax Institute on Audits and Tax Controversy, Thursday February 3, 2022, 10:00 a.m. – 11:30 a.m. (EST). The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions.  The reviews are expected to include […] Read More…

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SANDRA BROWN to Speak at Upcoming ABA Virtual 2022 Midyear Tax Meeting

We are pleased to announce that Sandra R. Brown will be presenting at the upcoming American Bar Association Virtual 2022 Midyear Tax Meeting, Tuesday, February 1, 2022, 2:30 p.m. – 3:00 p.m. (ET).  Sandra will provide updates on “Important Criminal Developments” on behalf of the Tax Section’s Civil and Criminal Tax Penalties (CCTP) Sentencing Subcommittee.   […] Read More…

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FinCEN Proposed Regulations Put “Transparency” in the Corporate Transparency Act by Requiring Disclosure of Beneficial Owners of LLCs and Other Entities By EVAN J. DAVIS

The dirty little secret, that isn’t so secret after the release of the Pandora Papers (Pandora Papers – ICIJ), is that the United States is a tax and money-laundering haven for much of the world because, unlike most countries, many U.S. states allow persons to own entities without revealing their ownership to authorities.  Last month, […] Read More…

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STEVEN TOSCHER, DENNIS PEREZ, MICHEL STEIN and SANDRA BROWN to Speak at Upcoming USC Gould School of Law 2022 Tax Institute

Please join us January 24-26, 2022 for the USC Gould School of Law 2022Tax Institute virtual event. Meet with fellow tax professionals and address the cutting-edge tax issues affecting the industry. This three-day institute includes discussions, networking opportunities, breakout sessions and workshops led by heavy hitters in the field. We have an excellent line up of programs – […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to Speak on Tax Reporting of Cryptocurrency

We are pleased to announce that Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming Strafford Webinar on Tax Reporting of Cryptocurrency: Calculating Basis, Income, and Gain, Thursday, January 20, 2022, 10:00 a.m. – 11:50 a.m. (PST). This course will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and […] Read More…

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Just When You Thought It Was Safe to Go into the Water, Along Comes the Fifth Circuit by ROBERT S. HORWITZ

I previously blogged on the Ninth Circuit’s decision in United States v. Boyle, 991 F.3d 1077 (2021), where the Court held the $10,000 non-willful FBAR penalty applies on a per-form rather than per-account basis.  Several district courts had reached the same conclusion, including the district court in United States v. Bittner, 469 F.Supp.3d 709 (ED […] Read More…

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MICHEL STEIN Quoted in Tax Notes Article Cryptocurrency Soft Letters Yield Big Bang for the Buck

The IRS is getting more information from its cryptocurrency exchange John Doe summonses, which it will use to fuel another round of soft letters to account holders, according to an agency official. Michel R. Stein of Hochman Salkin Toscher Perez PC noted that the Coinbase summons used older tax years but the same dollar threshold […] Read More…

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SANDRA BROWN to Speak at Upcoming Practising Law Institute Seminar at the Beverly Hills Marriott

We are pleased to announce that Sandra Brown along with Sharyn Fisk, IRS Office of Professional Responsibility, Caroline D. Ciraolo, and Bradley M. Seltzer will be speaking at the upcoming PLI Institute Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021 LA webinar, on “Balancing Tax Planning, Advocacy and Professional Ethics: The Rules That Every Tax Advisor […] Read More…

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STEVEN TOSCHER TO Speak at Upcoming University of Texas 69th Annual Taxation Conference

We are pleased to announce that Steven Toscher along with Larry Campagna, Honorable Elizabeth Copland and Charles Muller III will be speaking at the upcoming University of Texas 69th Annual Taxation Conference webinar, on “What Does Enforcement Look Like Today?” on Thursday December 2, 2021, 1:30 p.m. – 3:00 p.m.(CST). While Congress debates whether to fund more IRS enforcement, the […] Read More…

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SANDRA BROWN to Speak at Upcoming Freeman Law International Tax Symposium

We are pleased to announce that Sandra Brown will be speaking at the upcoming Freeman Law International Tax Symposium webinar, on “International Criminal Tax” on Friday, November 19, 2021, 9:25 a.m. – 10:15 a.m. (CST). The United States and other countries have increased focus on investigating and prosecuting international tax crimes.  With the rise of […] Read More…

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EVAN DAVIS Quoted in The Information on Coinbase Earnings Preview; Infrastructure Bill’s Crypto Reporting Rules

Coinbase will report its third-quarter earnings on Tuesday, likely giving more insight into its new offerings, such as its recently announced non-fungible token marketplace. The company, which is the largest crypto exchange in the U.S. by trading volume, could also announce new ventures as it expands further into financial services. It likely won’t be a big […] Read More…

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DENNIS PEREZ to Speak on The California Exodus: How to Exit the State with Your Fortune Intact (or Not)

We are pleased to announce that Dennis Perez will be speaking at the upcoming Professional Advisory Network of the Motion Picture and Television Fund webinar, on “The California Exodus: How to Exit the State with Your Fortune Intact (or Not)” on Thursday November 11, 2021, 12:20 p.m. – 1:28 p.m. (PST). Spurred by increasing taxes, crippling regulations and high-profile tech […] Read More…

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