TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 08, 2024

Want to know what keeps many tax controversy practitioners up at night? Representing taxpayers faced with parallel tax investigations certainly makes the list!  We are pleased to announce that Sandra R. Brown and Hunter Keaster wrote an article published in the Summer, 2024 issue of the the Journal of Tax Practice & Procedure, titled “Criminal, Civil, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 07, 2024

We are pleased to announce that Michel R. Stein, Evan Davis and Philipp Behrendt will be speaking at the upcoming CalCPA Cryptocurrency Compliance webinar, Tuesday, August 13, 2024, 9:00 a.m. – 10:30 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance for calculating and reporting income and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 24, 2024

We are pleased to announce that Jonathan Kalinski along with Ani Galyan (Galyan Law) will be speaking at an upcoming Strafford webinar on Tax Implications of Reclassifying Cannabis From a Schedule I to a Schedule III Drug, Tuesday, July 30, 2024, 10:00 a.m. – 11:30 a.m. (PST). This webinar will provide tax professionals guidance on key […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 22, 2024

In the ever-evolving financial technology landscape, virtual currencies, now more broadly termed “digital assets,” have emerged as a significant challenge for tax administration. The Treasury Inspector General for Tax Administration (TIGTA) recently released a comprehensive report titled “Virtual Currency Tax Compliance Enforcement Can Be Improved” (Report Number: 2024-300-030, dated July 10, 2024).  This report provides […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 18, 2024

We are pleased to announce that Philipp Behrendt will be speaking on two  upcoming Beverly Hills Bar Association programs focused on the Review of New IRS Regulations on Digital Asset Transaction Reporting for Brokers, which will address the following topics: July 23, 202410:00 a.m. – 11:30 p.m. (PST)Application to the Broker and the Reporting Itself […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 16, 2024

We are pleased to announce that Cory Stigile and Philipp Behrendt will be speaking at the upcoming CalCPA 2024 Annual Income Tax Seminar, Friday, July 26, 2024, 8:00 a.m. – 1:45 p.m. (PST) on the following topics: Cory StigileNew Enforcement Considerations This session will cover the impacts of non-compliance, responding to IRS subpoenas, and recent penalty […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, July 12, 2024

We are pleased to announce that Sandra R. Brown will be receiving the prestigious Richard Carpenter Excellence in Tax Award from the USD School of Law – RJS LAW Tax Controversy Institute. The Award is being presented at the 9th Annual USD School of Law – RJS LAW Tax Institute taking place July 19th in San […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, July 12, 2024

On June 20, 2024, the Supreme Court issued its decision in Moore v. United States, 603 U.S. ___, upholding the constitutionality of the Mandatory Repatriation Tax (“MRT”). While it was pending, the case was the subject of more commentary than any tax case in recent memory. Many commentators were in a twitter that a ruling in favor […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 11, 2024

On July 1, the Supreme Court issued its opinion in Corner Post, Inc. v. Federal Reserve Board, 603 U.S. ____ (2024), its second major decision in four days that expanded the ability of aggrieved parties to challenge federal agency regulations, including tax regulations. Under 28 U.S.C. §2401(a), a person has six years within which to file a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 10, 2024

Forty years ago, the Supreme Court in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., articulated a new test for determining the deference to be given to an agency’s interpretation of a statute. The Chevron Doctrine, as it came to be known, became a fixture of federal jurisprudence. In Mayo Foundation v. United States, the Court […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 08, 2024

We are pleased to announce that Edward M. Robbins, Jr., Robert S. Horwitz and Michael Greenwade will be speaking at the upcoming Strafford webinar “Foreign Information Return Penalties After Farhy: Impact of DC Circuit Court Decision” Thursday, July 18, 2024, 10:00 a.m. – 11:50 a.m. (PST). In Farhy v. Commissioner 160 T.C. No. 6 (T.C. Apr. 3, 2023), […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 03, 2024

Beware of the latest scheme targeting clean energy tax credits, the IRS cautions on July 3, 2024 (IR-2024-182). This scheme, preying on the well-meaning yet unsuspecting, involves tax return preparers who allegedly  misrepresent the rules for claiming clean energy tax credits under the Inflation Reduction Act (IRA). This is important not only for tax administration […] Read More…