Our Blog

See What Procedurally Taxing is Saying About the New Nominee for IRS Commissioner CHARLES RETTIG

Procedurally Taxing February 20, 2018 by: Keith Fogg The press reports that President Trump would nominate Chuck Rettig as the new IRS Commissioner were followed with a formal announcement. Assuming he is confirmed, Mr. Rettig will serve as the first tax lawyer in this position in the new millennium. I applaud the return to having someone run the … Continue reading See What Procedurally Taxing is Saying About the New Nominee for IRS Commissioner CHARLES RETTIG

Read More

We Are Pleased to Announce That LACEY STRACHAN Has Been Named Principal Of Our Firm

Lacey Strachan concentrates her practice in complex civil tax litigation and criminal tax prosecutions (jury and non-jury) before the federal district courts, the U.S. Tax Court, the U.S. Court of Federal Claims, and the Ninth Circuit Court of Appeals. Ms. Strachan represents individuals, corporations, pass-through entities, trusts, and estates in all stages of state and … Continue reading We Are Pleased to Announce That LACEY STRACHAN Has Been Named Principal Of Our Firm

Read More

Cryptocurrency Tax Webinar Hosted By Colleagues Of IRS Nominee Charles Rettig by Matthew De Silva of ETHNews.COM

On February 15, 2018, tax attorneys Steven Toscher and Michel R. Stein, principals at Hochman Salkin Rettig Toscher & Perez P.C., delivered a presentation entitled “New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment.” Earlier this month, President Trump nominated Charles Rettig, one of Toscher and Stein’s colleagues, to serve as commissioner of … Continue reading Cryptocurrency Tax Webinar Hosted By Colleagues Of IRS Nominee Charles Rettig by Matthew De Silva of ETHNews.COM

Read More

STEP/LA Luncheon Presentation featuring STEVEN TOSCHER – Festival of Forms Featuring Form 5471 Substantial Compliance Rules

  Friday, February 16, 2018 12:00 p.m. – 1:30 p.m. Northern Trust 2049 Century Park East, Suite 3600 Los Angeles, CA 90067 Steven Toscher of Hochman Salkin Rettig Toscher & Perez and John Apuzzo of PricewaterhouseCoopers LLP, will discuss an interesting topic about the encore presentation the Strafford webinar, “Form 5471 Substantial Compliance Rules: New … Continue reading STEP/LA Luncheon Presentation featuring STEVEN TOSCHER – Festival of Forms Featuring Form 5471 Substantial Compliance Rules

Read More

FOR IMMEDIATE RELEASE – President Trump Announces Intent to Nominate CHARLES P. RETTIG to be the Next Commissioner of Internal Revenue

HOCHMAN SALKIN RETTIG TOSCHER AND PEREZ, PC is honored to announce that President Trump has announced his intention to nominate Charles P. (“Chuck”) Rettig to become the next Commissioner of the Internal Revenue Service.  If confirmed by the U.S. Senate, Chuck would be the 49th IRS Commissioner, the first “tax person” to assume that position … Continue reading FOR IMMEDIATE RELEASE – President Trump Announces Intent to Nominate CHARLES P. RETTIG to be the Next Commissioner of Internal Revenue

Read More

Criminal Tax Restitution Order Overcomes Later IRS Settlement by Robert S. Horwitz

The Government routinely seeks a restitution order in criminal tax cases. When a defendant pleads guilty to a tax crime, the U.S. will either require the taxpayer to agree to a restitution amount or acknowledge that the U.S. can request restitution as part of the sentence.  Once the restitution order is entered, the defendant cannot … Continue reading Criminal Tax Restitution Order Overcomes Later IRS Settlement by Robert S. Horwitz

Read More

Sentencing in Tax Cases: It Ain’t That Bad (for Defendants) by Robert S. Horwitz

The Federal Sentencing Commission keeps track of sentencing in federal criminal cases. Its recently released Data Report gives an idea of sentences in criminal tax cases and how they stack up against sentencing in other types of federal criminal cases.  First, some basics. The report is for the fourth quarter of 2017. Since the U.S. … Continue reading Sentencing in Tax Cases: It Ain’t That Bad (for Defendants) by Robert S. Horwitz

Read More

Tax Court Reverses Itself, But The Taxpayer Still Loses by Robert S. Horwitz

On November 20, 2017, the Tax Court issued its opinion in Graev v. Commissioner, 149 T.C. __, reversing a prior decision that sustained a 20% accuracy penalty.  The issue before the Court was whether the IRS has to prove that it complied with Internal Revenue Code §6751(b)(1) in order to sustain a penalty in a deficiency … Continue reading Tax Court Reverses Itself, But The Taxpayer Still Loses by Robert S. Horwitz

Read More

WEBINAR featuring Steven Toscher and Michel Stein – New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment

New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment Strafford  February 15, 2018 – 10:00 a.m. – 11:30 p.m. (Pacific) On February 15 Steven Toscher and Michel Stein will be hosting a Strafford Webinar “New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment”   The panel will provide tax counsel, accountants and other advisers with … Continue reading WEBINAR featuring Steven Toscher and Michel Stein – New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment

Read More

WEBINAR featuring Michel Stein – FBAR 2018 Update: Mastering FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions

FBAR 2018 Update: Mastering FinCen Form 114 Deadlines, Extension, Penalty Resolution and Waiver Provisions Strafford  February 1, 2018 – 10:00 a.m. – 11:50 p.m. (Pacific) On February 1 Michel Stein will be hosting a Strafford Webinar “FBAR 2018 Update: Mastering FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions”  The IRS announced more changes to the filing requirements … Continue reading WEBINAR featuring Michel Stein – FBAR 2018 Update: Mastering FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions

Read More

Tax Court to IRS: You’re Too Late Baby! by Robert S. Horwitz

As part of its crackdown on taxpayers who were not reporting income from overseas assets, in 2010 Congress enacted Internal Revenue Code sec. 6038D. That section requires a taxpayer to provide information about “specified foreign financial assets.”  It applies to tax years beginning after March 18, 2010.  The IRS developed Form 8938, Statement of Specified … Continue reading Tax Court to IRS: You’re Too Late Baby! by Robert S. Horwitz

Read More

IRS’s FY 2017 Annual Report Blog #1: The IRS Appropriately Resets Its Criminal Priorities by Evan J. Davis

This is the first in a series of blogs that will analyze the IRS’s Fiscal Year 2017 Annual Report. This blog will focus on the shift away from easy cases in favor of harder cases such as foreign-account and hidden-income cases that most consider the core of IRS criminal enforcement. Later blogs will take a … Continue reading IRS’s FY 2017 Annual Report Blog #1: The IRS Appropriately Resets Its Criminal Priorities by Evan J. Davis

Read More