TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, September 03, 2021

We are pleased to announce that Sandra Brown along with John Colvin, Monique (Mimi) R. Gabel, Sarah E. Paul and Cliff Scherwinski will be speaking at the upcoming ABA Section of Real Property, Trust & Estate Law eCLE webinar, “Practitioners Guide to IRS High Income/High Wealth Audits” on Wednesday, September 15, 2021, 10:00 a.m. – 11:30 a.m. (PST) | 1:00 p.m. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, September 01, 2021

We are pleased to announce that Michel Stein, and Sandra Brown along with Lois Dietrich, the Acting Director of the IRS’s Office of Promoter Investigations, will be speaking at the upcoming Strafford webinar, “IRS Promoter Investigations, Enforcement Actions, and Penalties: Syndicated Conservation Easements, Micro-Captives” on Tuesday, September 14, 2021, 10:00 a.m. – 11:30 a.m. (PST). This CLE/CPE webinar will guide tax professionals […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 31, 2021

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming CSTC webinar, “Partnership Audit Procedures for Tax Counsel” on Tuesday, September 1, 2021, 10:00 a.m. – 11:40 a.m. (PST). The IRS Large Business and International Division stated in its most recent Focus Guide that an increase […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 26, 2021

We are pleased to announce that Dennis Perez, Michel Stein and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar, “Employment Tax Matters: Worker Classification and AB5″” on Tuesday, August 31, 2021, 9:00 a.m. – 10:00 a.m. (PST). The IRS increases both civil and criminal enforcement against taxpayers who fail to comply with withholding […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, August 23, 2021

At a recent Stafford webinar on NFTs, Jonathan Kalinski of Hochman Salkin Toscher Perez PC advised practitioners to be cautious in their positions. Just because there is no law on a new cryptoasset question doesn’t mean that the IRS can’t argue that “you should have known better” down the road. Crypto audits are ramping up, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, August 16, 2021

On July 28, 2021, the Internal Revenue Service (IRS) and the Department of Justice (DOJ) announced that it had obtained a Court Order authorizing summonses for records relating to U.S. Taxpayers who used Panama Offshore Service Providers (POLS) to hide assets and evade taxes.[i]   The issuance of these “John Doe” summonses will permit the IRS […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 04, 2021

We are pleased to welcome everyone back to an in person meeting for the ABA 38th National Institute on Criminal Tax Fraud and Eleventh Civil Tax Controversy which will again take place in Las Vegas Nevada on December 8-10. We are all looking forward to getting together and continuing the long tradition of outstanding panelists and government […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 03, 2021

We are pleased to announce that Jonathan Kalinski along with Jordan Bass will be speaking at the upcoming Strafford webinar, “Tax Treatment of Non-Fungible Tokens: Applicable Tax Rules, Characterization Issues, Crypto Transactions” on Tuesday, August 10, 2021, 10:00 a.m. – 11:30 a.m. (PST). This CLE/CPE webinar will provide tax counsel, accountants, and other advisers with […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, August 02, 2021

We are pleased to welcome everyone back to an in person meeting for the 37th UCLA Extension Tax Controversy Institute which will be on held on October 21st, at the Beverly Hills Hotel in Beverly Hills, California. We have another great line up of esteemed panelists and government speakers who will presenting on a full […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 21, 2021

The Second Circuit recently joined the Fourth (United States v. Horowitz), Eleventh (United States v. Rum) and Federal Circuits (Norman v. United States) in holding that the 1987 regulation setting the maximum penalty for willful FBAR violations at $100,000 was invalid due to the 2004 statutory amendment that provides that Treasury may impose a maximum […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 20, 2021

On May 20, 2021, the U.S. Treasury published a report entitled “The American Families Plan Tax Compliance Agenda.”[1]  The 22-page report reiterates previously-announced proposals by the Biden administration focused on increasing and improving tax compliance, including increasing information reporting by banks with respect to cryptocurrencies and additional financial transactions, and increasing the budget of the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 20, 2021

At one point or another, you may have heard that California has an $800 per year tax for businesses in California. But what is this tax and to which business does it apply to? California has an annual franchise tax. Every corporation that: is incorporated under the laws of California; is qualified to transact intrastate […] Read More…