TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, September 21, 2023

We are pleased to announce that an article entitled “Walking the Tightrope of Employment Tax Law,” by Jonathan Kalinski and Dennis Perez, is featured as the Los Angeles Lawyer Magazine’s September 2023 Cover Story. The article discusses both federal and California worker classification issues and the different standards for each. Now that California has adopted the ABC […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, September 15, 2023

We are pleased to announce that Steven Toscher, Michel Stein, and Robert Horwitz will be speaking at the upcoming Strafford webinar “Federal and State Tax Residency Rules: Latest IRS Examination Guidance and Navigating State Tax Regulations” Thursday, September 21, 2023, 10:00 a.m. – 11:50 a.m. (PST). This course will guide tax professionals and advisers on the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, September 08, 2023

Nestled in the heart of the Caribbean, Puerto Rico beckons with its breathtaking natural beauty, vibrant culture, and alluring lifestyle, making it a tempting living space for those seeking a tropical paradise while enjoying the benefits of living in a U.S. territory. However, those who move to Puerto Rico in whole or in part for […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, September 07, 2023

The year 2023 is witnessing transformative changes in the tax landscape for digital assets, with the Internal Revenue Service (IRS) poised to usher in a significant transformation. The official version of the proposed regulations for broker reporting under Code Secs. 6045 and 6045A is scheduled for August 29, 2023. However, ahead of this official release, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 29, 2023

Dear Colleague- We are pleased to announce that registration is now open for this years UCLA Extension Tax Controversy Institute which will be live this year and held on October 26, 2023 at the Beverly Hills Hotel in Beverly Hills, California.  The Institute is entering its 39th year and is recognized as one of the premier tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, August 28, 2023

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process” on Wednesday, September 6, 2023 from 10:00 a.m. – 11:30 a.m. (PST). The IRS employs strict standards for determining whether a taxpayer qualifies for penalty […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 22, 2023

We are pleased to announce that Sandra R. Brown will be speaking on upcoming seminars at the 40th Symposium on Economic Crime – Jesus College, University of Cambridge, being held at Jesus College, a College within the University of Cambridge, September 3–10, 2023. Sandra will be participating on the following panels Recent United States initiatives to enforce integrity Tuesday, September 4, 2023, 4:15 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 15, 2023

This column summarizes recent developments in the IRS’s civil enforcement of the employee retention credit (ERC), with a focus on its examinations. The IRS has been active in alerting taxpayers and tax professionals regarding attempts to promote ERCs to ineligible taxpayers, recently including ERC schemes on its 2023 Dirty Dozen list (News Release IR-2023-71). Click […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, August 12, 2023

In a recent announcement, titled: “IRS cautions plan sponsors to be alert to compliance issues associated with ESOPs” (IR-2023-114, dated August 9, 2023), the Internal Revenue Service (IRS) highlighted its expanded efforts to ensure high-income taxpayers pay their fair share of taxes. The focus of this announcement is on compliance issues associated with Employee Stock […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 10, 2023

Introduction: The recent case of Farhy v. Commissioner has brought attention to an essential aspect of the tax collection process – the assessment authority for penalties by the Internal Revenue Service (IRS). Ed Robbins, who argued this case on behalf of the taxpayer, explains the impact of this taxpayer’s victory in the latest volume of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, August 07, 2023

In an effort to combat tax evasion and abusive tax transactions, the Internal Revenue Service (IRS) and the U.S. Treasury Department have recently released proposed regulations targeting monetized installment sale transactions. These transactions, along with substantially similar schemes, have been classified as listed transactions—a category of reportable transactions that requires special disclosure and reporting. Click […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 04, 2023

We are pleased to announce that Philipp Behrendt will be speaking at the upcoming California Lawyers Association webinar “The Use of AI for Tax Litigation,” Tuesday, August 8, 2023, 12:00 p.m. – 1:00 p.m. (PST). The webinar will delve into the transformative impact of artificial intelligence on tax litigation practices. Attendees can look forward to gaining valuable […] Read More…