Our Blog

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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DOJ’s Tax Division Updates Criminal Tax Manual to Address Marinello’s Impact on Charging Decisions – by SANDRA R. BROWN and GARY MARKARIAN

On March 21, 2018, the Supreme Court issued its much awaited decision in Marinello, and in doing so, imposed significant limitations on the government’s ability to bring obstruction charges in tax cases under the so-called Omnibus Clause of 26 U.S.C. § 7202(a).  Since that time, tax practitioners have been watching to see how impactful the […] Read More…

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DENNIS PEREZ, MICHEL STEIN and JONATHAN KALINSKI to Speak on Resolving Employment Tax Disputes

We are pleased to announce that three of our principals Dennis Perez, Michel Stein and Jonathan Kalinski will be speaking at the upcoming CPAacademy webinar on Resolving Employment Tax Disputes Thursday, July 23, 2020, 1:00 pm PST. The IRS is increasing both civil and criminal enforcement against taxpayers who fail to comply with withholding and […] Read More…

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STEVEN TOSCHER to Moderate and Speak at the Upcoming Fifth Annual USD School of Law – RJS Law Tax Controversy Institute (Update)

Hope everybody is having a good weekend and staying safe.  I wanted to send out a reminder for the upcoming University of San Diego School of Law – RJS Law Tax Controversy Institute on Friday, July 17, 2020, from 10:30 am to 2:45 p.m. (PST). This year the program will be a webinar and will be complimentary for […] Read More…

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Fifth Circuit Rules Virtual Currency Transactions and Records Held By Exchanges Do Not Have Fourth Amendment Protections from Search and Seizure by the Government By: SANDRA R. BROWN and TENZING TUNDEN

The IRS had not been shy about highlighting that taxpayers need to report any and all virtual currency transactions appropriately and that it will use its enforcement tools to ensure such compliance.[i]  The IRS’s data-gathering efforts are part of those enforcement tools.   In 2017, the Government used a John Doe Summons to obtain a judicial […] Read More…

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MICHEL STEIN to Speak at the Upcoming STEP LA Webinar on PPP Program Loans

We are pleased to announce that Michel Stein will be speaking at the STEP LA Webinar–Payroll Protection Program Loans: Calculating the Loan Forgiveness Amount, Analysis of Legal Risks of Certifications, Representations in Applicants and Loan Documents, Tax Treatment, SBA Audit Risks, Appeals and Criminal Exposures — on Tuesday, July 14th from 7:30 a.m. – 9:30 […] Read More…

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Court Update: Day Late and a (Million) Dollar(s) Short by JONATHAN KALINSKI

On the eve of filings lawyers often stay awake at night hoping everything goes right.  Occasionally something goes wrong, you just hope it doesn’t happen to you.  Add one more horror story to the list.  In a harsh result, the Ninth Circuit held that the Tax Court correctly dismissed as untimely Organic Cannabis Foundation’s petition.[1] […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and JONATHAN KALINSKI to speak on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques (Discounted Price)

We are pleased to announce that Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the Spidell Webinar–Taxation of Cannabis— on Thursday July 9th  at 10:00 a.m. – 12:00 p.m.  The cannabis business has been growing at very fast pace in California and other jurisdictions since legislative changes legalizing and regulating the sale, […] Read More…

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