TAXLITIGATOR Blog

STEVEN TOSCHER and MICHEL R. STEIN to Speak at Upcoming Strafford Webinar – IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process

STEVEN TOSCHER and MICHEL R. STEIN to Speak at Upcoming Strafford Webinar – IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process

We are pleased to announce that Steven Toscher, Michel R. Stein and Thomas M. Giordano-Lascari (Greenberg Glusker) will be speaking at the upcoming Strafford webinar “IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process” Tuesday, May 28, 2024, 10:00 a.m. – 11:30 a.m. (PST). The IRS has and continues to […] Read More…

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SANDRA R. BROWN Quoted in Tax Notes on What the IRS’s 2024 ‘Dirty Dozen’ List Tells Us About Tax Administration

SANDRA R. BROWN Quoted in Tax Notes on What the IRS’s 2024 ‘Dirty Dozen’ List Tells Us About Tax Administration

Sandra R. Brown was quoted in a May 6, 2024 Tax Notes Article on What the IRS’s 2024 ‘Dirty Dozen’ List Tells Us About Tax Administration, authored by Kathy A. Enstrom, Moore Tax Law Group, LLC.  The IRS annually releases its “Dirty Dozen” list to warn taxpayers and tax practitioner alike of various tax scams as […] Read More…

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The IRS Criminal Investigation Division Braces for a Surge of Criminal Charges in Crypto Tax Cases – This Year and Going Forward by SANDRA R. BROWN, EVAN DAVIS & PHILIPP BEHRENDT

The IRS Criminal Investigation Division Braces for a Surge of Criminal Charges in Crypto Tax Cases – This Year and Going Forward by SANDRA R. BROWN, EVAN DAVIS & PHILIPP BEHRENDT

In a recent interview with CNBC at the Chainalysis Links event in New York, Guy Ficco, a Chief of the IRS Criminal Investigation Division (IRS-CI), issued a stark warning: the IRS is gearing up to tackle a significant increase in cases of tax fraud and evasion related to cryptocurrency transactions. Ficco’s words carry weight, especially […] Read More…

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STEVEN TOSCHER, MICHEL R. STEIN and CORY STIGILE to Speak at Upcoming Strafford Webinar on IRS High-Wealth Examinations

STEVEN TOSCHER, MICHEL R. STEIN and CORY STIGILE to Speak at Upcoming Strafford Webinar on IRS High-Wealth Examinations

We are pleased to announce that Steven Toscher, Michel R. Stein and Cory Stigile will be speaking at the upcoming Strafford webinar “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals, and Litigation” Wednesday, May 15, 2024, 10:00 a.m. – 11:50 a.m. (PST). The IRS Large Business and International Division is auditing high net […] Read More…

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SANDRA R. BROWN to Speak at ABA Loretta Argrett Fellows Webinar

SANDRA R. BROWN to Speak at ABA Loretta Argrett Fellows Webinar

We are pleased to announce that on May 17, 2024, Sandra R. Brown, along with Gwen Moore (Moore Tax Law Group), Jennifer Breen (Morgan Lewis), and Pamela Grewal (Andersen Tax), will join a webinar with the Loretta Collins Argrett fellows and leadership to discuss navigating their career transitions and what it means to be a […] Read More…

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SAVE THE DATE – ABA Criminal Tax Fraud/Tax Controversy Conference – December 12-14, 2024

SAVE THE DATE – ABA Criminal Tax Fraud/Tax Controversy Conference – December 12-14, 2024

My co-chair, Kathy Keneally and I are very pleased to ask you to save the date for the ABA 2024 Criminal Tax Fraud/Tax Controversy conference, to be held this year at the Wynn Encore on December 12-14, 2024.  The program is still in the planning stage, but we can assure you that we continue to build […] Read More…

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STEVEN TOSCHER, MICHEL R. STEIN and EVAN DAVIS to Speak at Upcoming CalCPA – Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations

STEVEN TOSCHER, MICHEL R. STEIN and EVAN DAVIS to Speak at Upcoming CalCPA – Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations

We are pleased to announce that Steven Toscher, Michel R. Stein and Evan Davis will be speaking at the upcoming Strafford webinar “Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations” Thursday, May 9, 2024, 10:00 a.m. – 11:30 a.m. (PST). The IRS continues to press its concern over “massive under-reporting” of income from cryptocurrency transactions, including […] Read More…

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American Bar Association Awards Jules Ritholz Memorial Merit Award to STEVEN R. TOSCHER

American Bar Association Awards Jules Ritholz Memorial Merit Award to STEVEN R. TOSCHER

Steven Toscher, the managing principal for Hochman Salkin Toscher Perez P.C., has received the Jules Ritholz Memorial Merit Award from The American Bar Association’s (ABA) Tax Section Civil and Criminal Tax Penalties Committee. The award was presented during ABA’s 2024 May Tax Meeting, held in Washington, DC. on May 3, 2024.  Click Here to Read […] Read More…

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California Lawyers Association – 2024 Washington D.C. Delegation – April 30, 2024 – May 1, 2024

California Lawyers Association – 2024 Washington D.C. Delegation – April 30, 2024 – May 1, 2024

We are pleased to announce that Jonathan Kalinski and Philipp Behrendt of our firm participated in the California Lawyers Association – Taxation Section’s Washington, D.C. Delegation on April 30 and May 1, 2024. For over 30 years, the Taxation Section has annually selected a delegation to advocate for California tax lawyers’ ideas and proposals to […] Read More…

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IRS Firm on Reporting: Form 1099-DA Unveiled, Compliance Unwavering by PHILIPP BEHRENDT

IRS Firm on Reporting: Form 1099-DA Unveiled, Compliance Unwavering by PHILIPP BEHRENDT

The IRS published the first draft of the 1099-DA with supplementary information on 4/22/2024 (89 FR 29433). The Form 1099-DA will be used by digital asset brokers to report transactions of US taxpayers, similar to the Form 1099-DIV brokers and banks issue every year. Back in November 2021, the Infrastructure Investment and Jobs Act (“IIJA”) […] Read More…

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SANDRA R. BROWN to Speak at Upcoming ABA May Tax Meeting on The Importance of Interview Notes in Criminal Matters, From Investigation Through Sentencing – May 4, 2024

SANDRA R. BROWN to Speak at Upcoming ABA May Tax Meeting on The Importance of Interview Notes in Criminal Matters, From Investigation Through Sentencing – May 4, 2024

We are pleased to announce that Sandra R. Brown will be moderating a panel at the upcoming ABA Tax Section 2024 May Tax Meeting on the on the topic of “The Importance of Interview Notes in Criminal Matters, From Investigation Through Sentencing” on Saturday, May 4, 2024, 10:30 a.m. (EST), along with co-panelists, Michael Kelly (Akerman […] Read More…

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PHILIPP BEHRENDT Quoted in Tax Notes – Does the IRS Get a Percentage After a Crypto 51 Percent Attack?

PHILIPP BEHRENDT Quoted in Tax Notes – Does the IRS Get a Percentage After a Crypto 51 Percent Attack?

Philipp Behrendt was quoted in Tax Notes Article on the question whether the IRS get a percentage after a crypto 51 percent attack (Posted on Apr. 16, 2024, by Nathan J. Richman and Mary Katherine Browne). The article explores the question whether the IRS position on the worthlessness of digital asset is applicable to losses […] Read More…

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