Our Blog

No Mulligan for Tax Offender, Penalties and Interest Count for Criminal Tax Loss, but Restitution Doesn’t Include Tax Says Second Circuit by EVAN J. DAVIS

Do-overs are rare in criminal law, unlike a weekend golf game.  Finality is an important factor in what appellate courts do, which is why they establish hard-to-meet standards for reversal such as “plain error.”  Another tip: judges don’t like defendants to use the time between pleading guilty and being sentenced to commit the same crimes […] Read More…

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State Tax Agencies Preparing for Increased Transfer Pricing Enforcement by STEVEN TOSCHER, LACEY STRACHAN and TENZING TUNDEN

Transfer pricing tax disputes are the highest dollar for dollar cases that are before the U.S Tax Court currently, with cases that involve cross-border transactions of large multinational corporations. These are particularly important tax matters for states where multinational corporations are headquartered and/or conduct business.  But transfer pricing controversies are not limited to large multinationals—the […] Read More…

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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to speak on Partnership Audit Adjustments Under the Centralized Audit Regime

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at an upcoming Strafford webinar, “Partnership Audit Adjustments Under the Centralized Audit Regime” for Wednesday, April 22, 2020, 1:00 p.m. – 2:50 p.m. EDT/ 10:00 a.m. – 11:50 a.m. PST This webinar will cover practical considerations for partners and […] Read More…

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ROBERT HORWITZ and CORY STIGILE to speak on COVID-19 Administrative and Legislative Relief

We are pleased to announce that two of our principals Robert Horwitz and Cory Stigile  will be speaking at the upcoming Beverly Hills Bar Association webinar on COVID-19 Administrative and Legislative Relief, Wednesday, April 8, 2020, 3:30 p.m.-4:30 p.m. This is a free webinar being presented by the Beverly Hill Bar Association as a public […] Read More…

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FTB, OTA Extend Filing Deadlines for Protests, Appeals, Briefing — Will Treasury Follow Suit by ROBERT S. HORWITZ

On March 30, 2020, the California Franchise Tax Board (FTB) issued Notice 2020-02.  Based on Governor Newson’s March 12, 2020, executive order authorizing the FTB to use its administrative powers to grant extensions, the notice extends the deadline for filing claims for refund, protests of Notices of Proposed Assessment (NPA), appeals and petitions for rehearing […] Read More…

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Report COVID-19

Be aware that criminals are attempting to exploit COVID-19 worldwide through a variety of scams. There have been reports of: • Individuals and businesses selling fake cures for COVID-19 online and engaging in other forms of fraud. • Phishing emails from entities posing as the World Health Organization or the Centers for Disease Control and […] Read More…

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IRS Announces New Campaign Targeting Rental Income for Nonresident Aliens by STEVEN TOSCHER and TENZING TUNDEN

The U.S. real property market has always been attractive to foreign investors, not just for it’s potential for profit, but also because of the country’s robust financial and legal system in case investors need to efficiently liquidate their ownership or if a dispute arises. For the 12 months ending in March 2016, NRAs purchased $43.5 […] Read More…

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Utilising the IRS Streamlined Compliance Programme to Manage US Tax Risk by STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN

United States (US) taxpayers living abroad who have not filed US tax returns should take steps now to minimise their tax risk before it is too late. Presently, the Internal Revenue Service (IRS) provides various options to correct one’s taxes in the form of disclosure initiatives. The opportunity to use one of these options may […] Read More…

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What Makes A Failure to File Your Tax Returns a Felony? by SANDRA BROWN

Serial Non-Filer Pleads Guilty to Tax Evasion[i] From 2009 through 2016, Daryl Brown received taxable income. Nonetheless, Mr. Brown did not file his tax returns to report his income nor did he pay the taxes he owed on such taxable income.  Mr. Brown did, however, take steps to evade his tax obligations, such as opening […] Read More…

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The IRS People First Initiative – A Unique Compliance Opportunity for Taxpayers through Collection Relief and Postponed Compliance Actions, by CORY STIGILE

The IRS unveiled a new “People First initiative” today in IR-2020-59 as part of a continued COVID-19 relief effort for taxpayers.  While a primary feature of the announcement is a targeted and significant suspension of collection enforcement and other compliance functions, the People First Initiative provides a rare opportunity for non-filers and procrastinators to get […] Read More…

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Micro-Captive Insurance – New IRS Enforcement Letters to Address Abuse Provide Opportunity for Some Taxpayers By: MICHEL STEIN

The Internal Revenue Service (IRS) began sending contact letters this week reminding certain taxpayers that it has their information relating to deductions claimed for micro-captive insurance arrangements. The letters also asked taxpayers who stopped claiming deductions to provide certain information under penalty of perjury, including the final year a micro-captive deduction was claimed.  As for […] Read More…

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The Government Implements Tax Credit for Small Businesses to Reimburse Paid Leave for Workers Affected by Coronavirus by AVRAM SALKIN and ROBERT HORWITZ

President Trump signed the Families First Coronavirus Response Act on March 18, 2020.  Division E of the Act provides for employers to be reimbursed dollar-for-dollar for coronavirus-affected paid sick leave and paid child care leave via payroll tax credits.  On March 20, the Treasury Department, the IRS and the Department of Labor announced plans for […] Read More…

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