The IRS has spent over a decade using and refining a model for bringing into compliance those taxpayers who made mistakes in good faith or through non-willful ignorance, and for punishing bad actors. The renewed push to target cryptocurrency builds on its predecessor, offshore bank accounts, but is distinguishable in important ways. The IRS appears sensitive to the differences, has more to […] Read More…
Last August, I blogged on the Court of Federal Claims (CFC) decision in the Mindy Norman FBAR willful penalty case. Rejecting the decisions in Colliot and Waldham, the CFC held that 31 CFR § 1010.820 (which limited the willful FBAR penalty to $100,000) was invalid due to the 2004 amendment to 31 U.S.C. §5321(a)(5). Disagreeing […] Read More…
We are pleased to announce that four of our principals will be speaking at the upcoming 36th Annual National Institute on Criminal Tax Fraud, December 11-13, 2019, Wynn, Las Vegas. Co-Chaired by Steven Toscher and Kathryn Keneally. This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax […] Read More…
We would like to encourage you to "save the date" for the following conferences where members of our firm will be speaking:
November 22, 2019
December 4-5, 2019
Headquartered in Beverly Hills, California, HOCHMAN SALKIN TOSCHER PEREZ P.C.,
serves a diverse client base throughout the United States.