TAXLITIGATOR Blog

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…

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

Dear Colleagues- We cordially invite you to register for the 2024 UCLA Extension Tax Controversy Institute, which will be held on October 24, 2024, at the Beverly Hills Hotel, Beverly Hills, California. The link for registration is below. The Institute has long been recognized as one of the premier tax controversy programs in the United States. Last year […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 02, 2024

We are pleased to announce that Robert S. Horwitz and Carneil Wilson (Dentons) will be speaking at the upcoming Beverly Hills Bar Association webinar “Moore v. US: What’s Next for International Taxation and American Shareholders” Tuesday, July 9, 2024, 12:30 a.m. – 1:30 p.m. (PST). The U.S. Supreme Court has upheld the constitutionality of the Mandatory […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, June 26, 2024

Consistent with its efforts to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, and large corporations, on June 17, 2024, the IRS unveiled a series of documents taking aim at basis shifting transactions by related-party partnerships. These documents are: Click Here for Full Article

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, June 24, 2024

We are pleased to announce that Edward M. Robbins, Jr. will also be speaking on June 26th at the Agostino & Associates International and Domestic Tax Controversy Update at the Bergen Community College at the Meadowlands. BBQ to follow at The Green at Hackensack Court Square on the topic of Farhy Update, Aroeste, Malta Pensions and what it portends for IRS […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 21, 2024

In Connelly v. United States, the U.S. Supreme Court examined an estate-tax issue involving how to value life insurance proceeds received by a closely held corporation upon a principal shareholder’s death. Typically, such proceeds are used by the corporation to buy back shares from the deceased shareholder’s estate, thereby keeping the corporation in the family. The parties […] Read More…