Our Blog

Law360 Tax Authority – Justices Asked To Uphold Attorney Privilege In Tax Client List Row

We are very proud to be part of the team that prepared the Supreme Court amicus brief on behalf of the American College of Tax Counsel seeking certiorari on this very important issue concerning IRS John Doe summonses and the attorney-client privilege and tax attorneys. Click Here to Read Full Article.

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak at Upcoming Webinar on Cryptocurrency Tax Compliance in the Post $30,000 Bitcoin World

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Spidell webinar, “Cryptocurrency Tax Compliance in the Post $30,000 Bitcoin World” on Wednesday, June 23, 2021, 10:00 a.m. – 12:00 p.m. (PST). The IRS is coming down on taxation of cryptocurrency. When you ask your client […] Read More…

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District Court Holds Listed Transaction Notice Exempt from Administrative Procedures Act by ROBERT HORWITZ

On May 13, 2021, the Supreme Court in CIC Services, Inc. v. Internal Revenue Service held that the Anti-Injunction Act did not bar an action to enjoin an IRS listed transaction notice because it allegedly failed to comply with the Administrative Procedures Act (“APA”) notice and comment provisions.  See, https://www.taxlitigator.com/and-now-for-something-completely-different-supreme-court-holds-suit-to-enjoin-irs-notice-not-barred-by-the-anti-injunction-act-by-robert-s-horwitz/.  On the same day, a […] Read More…

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13th Annual NYU Tax Controversy Forum to be held June 24 and 25, 2021

We are pleased to invite you to register now for the 13th Annual NYU Tax Controversy Forum Webinar to be held June 24 and 25.  You do not want to miss this program. Co-Chairs Bryan Skarlatos and Steven Toscher are pleased to announce this year’s NYU Tax Controversy Forum which will feature updates on what the IRS is doing to enhance compliance through […] Read More…

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EVAN DAVIS to Speak at Upcoming Webinar on Shining Light on Dirty Money: Corporate Transparency and Anti-Money Laundering Acts of 2020

We are pleased to announce that Evan Davis, along with Ian M. Comisky, Deborah L. Connor and Andrew Winerman will be speaking at the upcoming 13th Annual NYU Tax Controversy Forum webinar, “Shining a Light on Dirty Money: Corporate Transparency and Anti-Money Laundering Acts of 2020” on Friday, June 25, 2021, 3:30 p.m. – 4:30 p.m. (PST). Last year, Congress passed […] Read More…

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SANDRA BROWN to Speak at Upcoming Webinar on Focus on Tax Practitioners: Ethical and Penalty Issues

We are pleased to announce that Sandra Brown, along with Jonathan Black, Sharyn Fisk and Lois Dietrich will be speaking at the upcoming 13th Annual NYU Tax Controversy Forum webinar, “Focus on Tax Practitioners: Ethical and Penalty Issues” on Thursday, June 24, 2021, 3:00 p.m. – 4:00 p.m. (PST). Tax practitioners are the gatekeepers to the country’s tax system and are […] Read More…

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MICHEL STEIN, SANDRA BROWN and EVAN DAVIS to Speak at Upcoming Webinar on Cryptocurrency Tax Compliance in the Post $50,000 Bitcoin World

We are pleased to announce that Michel Stein Sandra Brown and Evan Davis will be speaking at the upcoming CalCPA webinar, “Cryptocurrency Tax Compliance in the Post $50,000 Bitcoin World” on Tuesday, June 15, 2021, 9:00 a.m. – 10:00 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and reporting […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to Speak at Upcoming Webinar on New Developments in Cryptocurrency Reporting and Enforcement

We are pleased to announce that Steven Toscher and Michel Stein will be speaking at the upcoming CSTC webinar, “New Developments in Cryptocurrency Reporting and Enforcement” on Wednesday, June 9, 2021, 10:00 a.m. – 11:40 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating […] Read More…

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FBAR Willful Cases Are Similar to Groundhog Day by ROBERT S. HORWITZ

Whenever I read a new FBAR willful penalty I get a distinct feeling of déjà vu all over again, to quote the great Yogi Berra.  Elements: Did the taxpayer have a foreign bank account – check. Did the taxpayer know of the foreign bank account – check Did the taxpayer fail to tell the return […] Read More…

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ROBERT HORWITZ Weighs in and Quoted in Tax Notes on the Scope of the Supreme Court’s Recent Decision in CIC and the Potential Impact on International Information Reporting Penalties and Proposals for More Expansive Information Reporting

The Biden administration’s vision for increased information reporting, depending on implementation specifics, may have a new obstacle to contend with: the Supreme Court’s recent decision shortening the reach of the Anti-Injunction Act (AIA). In its decision, the Supreme Court gave as one reason why the AIA did not apply was that there were several steps […] Read More…

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DENNIS PEREZ, SANDRA BROWN and CORY STIGILE to Speak at Upcoming Webinar on High-Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations

We are pleased to announce that Dennis Perez, Sandra Brown and Cory Stigile will be speaking at the upcoming Strafford webinar, “High-Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations” on Wednesday, June 2, 2021, 10:00 a.m. – 11:30 a.m. (PST), 1:00 p.m. – 2:30 p.m. (EST). This webinar will discuss the IRS’ recent […] Read More…

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SANDRA BROWN to Speak at Upcoming Oregon Tax Institute on John Doe Summonses: A Deeper Look at a Key IRS Information Gathering Tool and What Its Increased Use May Mean to Non-Compliant Taxpayers

We are pleased to announce that Sandra Brown will be speaking at the upcoming 21st Annual Oregon Tax Institute webinar, “John Doe Summonses: A Deeper Look at a Key IRS Information Gathering Tool and What Its Increased Use May Mean to Non-Compliant Taxpayers” on Friday, June 4, 2021, 2:50 p.m. – 3:50 p.m. (PST). In […] Read More…

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