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UCLA 36th Annual Tax Controversy Institute – Save the Date – October 20, 2020

The 36th Annual UCLA Extension Tax Controversy Institute is right around the corner on October 20th. This year the Institute will be virtual and we have an all star line up of Government representatives and private practitioners who will discuss the cutting edge issues in tax controversy. We are pleased to announce that Commissioner of Internal Revenue Charles P. […] Read More…

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SANDRA BROWN Quoted in in Wonderful LAW360 Article on Justice Ginsburg’s Legacy in Tax Cases

Law360 — Included in Justice Ruth Bader Ginsburg’s monumental legacy are several tax opinions in which she addressed whether a California corporate franchise tax violates the U.S. Constitution, how states can tax citizens and when employment taxes apply to baseball players’ back pay. Justice Ruth Bader Ginsburg in a panel discussion at Georgetown University Law […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to Speak on Handling LBI Wealth Squad Examinations and Related IRS Enforcement Issues for High Net Worth Individuals

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CPA Academy webinar on Handling LBI Wealth Squad Examinations and Related IRS Enforcement Issues for High Net Worth individuals  Thursday, September 29, 2020, 9:00 a.m. – 10:30 a.m. (PST). The Global High Wealth Group is an […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak on New Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming CPA Academy webinar on New Developments in Cryptocurrency – Reporting and Enforcement, Thursday, September 24, 2020, 2:00 p.m. – 3:00 p.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at […] Read More…

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STEVEN TOSCHER, ROBERT HORWITZ and SANDRA BROWN to Speak on Yes, You Actually Can Go to Jail for Not Paying Taxes

We are pleased to announce that Steven Toscher, Robert Horwitz and Sandra Brown will be speaking at the upcoming CPA Academy webinar on Yes, You Actually Can Go to Jail for Not Paying Taxes, Tuesday, September 22, 2020, 2:00 p.m. to 3:00 p.m. (PST). In recent years, pursuing criminal tax cases involving a taxpayer’s interference […] Read More…

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SANDRA BROWN Quoted in in LAW360 on IRS New Fraud Office

The novel coronavirus pandemic isn’t delaying the rampup of the Internal Revenue Service’s recently launched office to combat tax fraud, the office’s director told Law360 in a recent interview. The former head of the IRS criminal investigation unit is now the director of its new fraud enforcement office. (AP) Though the pandemic has affected the […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak on New Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming CalCPA webinar on New Developments in Cryptocurrency – Reporting and Enforcement, Tuesday, September 1, 2020, 9:00 a.m. to 10:30 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance […] Read More…

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Ninth Circuit Holds Annuities from a GRAT Were Includible in the Taxable Estate under Section 2036(a)(1) By: CORY STIGILE and TENZING TUNDEN

In Badgley v. U.S, 957 F.3d 969 (9th Cir. 2020), the9th Circuit addressed the unfortunate fact pattern when a taxpayer dies prior to the termination of a lengthy (15-year) grantor-retained annuity trust (“GRAT”).  As background, GRATs allow a grantor to transfer property to a beneficiary in trust while retaining the right to an annuity for […] Read More…

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IRS Enforcement Resumes – Examinations of Section 41 Research Credits by CORY STIGILE

Under the People First Initiative, the IRS asserted it would generally not start new examinations, except for situations with short statutes of limitations.  As the relief provisions of the People First Initiative waned after July 15, 2020, the IRS has resumed collection activities in earnest, and presumably will also begin new examinations.  The IRS has […] Read More…

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STEVEN TOSCHER Quoted in Regulatory Compliance Watch – Eight Years Later, Advisor’s Case Remains Frozen

For years, Beck Asset Management ($26M in AUM) in Zurich has made an unusual disclosure in its Form ADV out “of an abundance of caution.” The firm’s latest Form ADV reveals that “Josef Beck works as Investment Advisor for Beck Verwaltungen AG (“BVAG”), an entity that is under common control with Beck AM only because […] Read More…

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JONATHAN KALINSKI to Speak on Anatomy of a Tax Court Case

We are pleased to announce that Jonathan Kalinski will be speaking at the upcoming LawPracticeCLE webinar on Anatomy of a Tax Court Case, Friday, August 7, 2020, 2:00 p.m. – 4:00 p.m. (EST), 11:00 a.m. – 1:00 p.m. (PST). Everything you need to know about navigating the complex world of Tax Court litigation. The discussion […] Read More…

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STEVEN TOSCHER and JONATHAN KALINSKI to Speak on Criminal Tax Issues/Going Through an IRS Audit

We are pleased to announce that Steven Toscher and Jonathan Kalinski will be speaking at the upcoming CalCPA Cannabis Industry Virtual Symposium webinar on Criminal Tax Issues/Going Through an IRS Audit, Friday, August 7, 2020, 1:45 p.m. COVID-19 has wreaked havoc on the economy, and the cannabis sector was not immune. Supply chains and distribution were disrupted, revenues were […] Read More…

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