TAXLITIGATOR Blog
EVAN DAVIS Elected Fellow to the American College of Tax Counsel
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Tuesday, May 11, 2021
We are pleased to announce that Evan Davis has been elected as Fellow by the American College of Tax Counsel. Evan, a principal of our firm, joined us in 2016, after more than 20 years in the public sector as a trial lawyer with extensive civil and criminal trial and appellate experience in both federal and state […] Read More…
Read MoreSAVE THE DATE – 13th Annual NYU Tax Controversy Forum
Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, May 08, 2021
We are pleased to invite you to the 13th Annual NYU Tax Controversy Forum Webinar to be held June 24 and 25. You do not want to miss this program. Co-Chairs Bryan Skarlatos and Steven Toscher are pleased to announce this year’s NYU Tax Controversy Forum which will feature updates on what the IRS is doing to enhance compliance through communication and […] Read More…
Read MoreSTEVEN TOSCHER and MICHEL STEIN Podcast on the Tax Rep Network
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 05, 2021
On this week’s podcast, we’re chatting about cryptocurrency and enforcement. Joining the conversation is Michel Stein and Steven Toscher, who have previously participated before. If you’re a longtime listener, then you know it’s been more than 60 episodes since their last visit. Yet, whenever cryptocurrency and enforcement are hot topics of conversation, we happily strive […] Read More…
Read MoreTaxpayer’s Can’t File Petitions to Quash IRS Criminal Investigations Summonses to Third Parties By: ROBERT HORWITZ and TENZING TUNDEN
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 05, 2021
Richard and Kimberly Gaetano owned marijuana dispensaries. After a falling out with their legal advisor/business partner, he apparently ratted them out to IRS Criminal Investigations (“CI”). In 2017, they sued to bar CI from discussing attorney-client matters with their former legal advisor. That case was dismissed. Gaetano v United States, 942 F.3d 727 (6th Cir. […] Read More…
Read MoreThe IRS Remains Committed to Seeking Authorization to Serve John Doe Summonses for Information from Cryptocurrency Exchanges as it Targets Taxpayers Who Fail to Report Cryptocurrency TransactionsBY: SANDRA BROWN and TENZING TUNDEN
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 28, 2021
Why is it that tax compliance involving this emerging asset continues to be problematic? Aside from any individualized taxpayer’s confusion or potential motivations, one additional answer may be the direct result of the lack of third-party reporting requirements. While digital currency exchanges, under Title 31 and the Bank Secrecy Act, are generally regulated as money […] Read More…
Read MoreSTEVEN TOSCHER, MICHEL STEIN and ROBERT HORWITZ to Speak on Federal and State Residency Issues: Remote Workers and Navigating IRS Examination Guidance and State Regulations in the Post-Covid-19 World
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, April 23, 2021
We are pleased to announce that Steven Toscher, Michel Stein, and Robert Horwitz will be speaking at the upcoming Spidell webinar, “Federal and State Residency Issues: Remote Workers and Navigating IRS Examination Guidance and State Regulations in the Post-Covid-19 World” on Wednesday, May 5, 2021, 10:00 a.m. – 12:00 p.m. (PST). This webinar will cover […] Read More…
Read MoreJONATHAN KALINSKI Quoted in Tax Notes on IRS Inventory Accounting Memo Geared to Cannabis Industry
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 21, 2021
A recently released IRS legal memorandum appears to be intended to clarify inventory tax accounting principles for state-legal marijuana businesses despite not mentioning the restriction they face, according to practitioners. Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes in part that “Most taxpayers aren’t asking to capitalize costs to inventory and would rather […] Read More…
Read MoreDENNIS PEREZ and STEVEN TOSCHER to Speak on The (Tax) Truths and Consequences of Leaving California
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 19, 2021
We are pleased to announce that Dennis Perez and Steven Toscher will be speaking at the upcoming Jewish Community Foundation of Los Angeles webinar, “The (Tax) Truths and Consequences of Leaving California” on Wednesday, April 28, 2021, 12:00 p.m. – 1:30 p.m. (PST). This webinar will guide tax professionals and advisers on the latest California […] Read More…
Read MoreCourt Holds Dynamex ABC Test Does Not Apply for Unemployment Insurance Purposes Pre-2020, but Employer Still Loses BY: ROBERT HORWITZ and TENZING TUNDEN
Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, April 17, 2021
In September 2019, California enacted Assembly Bill 5, which codified the three part “ABC test” of Dynamex Operations West Inc. v. Superior Court, 4 Cal.4th 903 (2018), to determine whether workers are employees and not independent contractors. Under the ABC test a worker is presumed to be a common law employee unless the hiring entity […] Read More…
Read MoreJoin STEVEN TOSCHER in his recent podcast on IBFD Tax Takes: News and Views, where he is interviewed by Stu Gibson of IBFD on the current state of the taxation of cryptocurrency and IRS enforcement. Things are heating up.
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, April 16, 2021
The views: Steve Toscher (Managing Principal, Hochman Salkin Toscher Perez) and Stuart Gibson (Chief Editor, Global News and US, IBFD) discuss the main tax issues you should be aware of regarding virtual currency. They summarize the IRS’s public guidance on virtual currency, efforts within the United States to advise taxpayers of their reporting obligations, as […] Read More…
Read MoreSTEVEN TOSCHER and EVAN DAVIS to Speak at Upcoming ABA Webinar A New Regime of Transparency: Anti-Money Laundering and Corporate Transparency Acts of 2020 and Expansion of Cryptocurrency Reporting
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, April 16, 2021
We are pleased to announce that Steven Toscher will be moderating and Evan Davis will be speaking at the upcoming ABA webinar, “A New Regime of Transparency: Anti-Money Laundering and Corporate Transparency Acts of 2020 and Expansion of Cryptocurrency Reporting” on Tuesday, April 27, 2021, 1:00 p.m. (EST), 10:00 a.m. (PST).Joining the panel will be Andrew Winerman, Acting Deputy Associate Director of […] Read More…
Read MoreThe Good, the Bad and the Ugly FBAR Style by Robert Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, April 11, 2021
What does the title of one of Sergio Leone’s great Clint Eastwood westerns have to do with Foreign Bank Account Reports (known in the trade as “FBARS”) and FBAR penalties. Two significant court of appeal opinions and a district court opinion involving the FBAR penalty were issued recently (United States v. Boyd, __ F.3d __, […] Read More…
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