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JONATHAN KALINSKI to speak at the Beverly Hills Bar Association on AB 5 Aftermath: Tax, Employment, and Entertainment Fallout

We are pleased to announce that Jonathan Kalinski, along with David Pierce, Pierce Law Group, Greg Zbylut, Singer, Burke Zimmer, Lora Silverman, Ross & Silverman and Schuyler Moore, Greenberg Glusker, will be speaking on “AB 5 Aftermath: Tax, Employment, and Entertainment Fallout,” at Lawry’s The Prime Rib, Beverly Hills on Wednesday, October 2, 2019  at […] Read More…

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Court Confirms the IRS Can’t Get Blood from a Stone by EVAN J. DAVIS

For the most part, the deck is stacked in the IRS’s favor when it comes to enforcing administrative summonses.  It’s relatively easy for the government to show that it is entitled to enforcement of a summons through submitting a declaration from an IRS employee that states (often with no supporting facts): The investigation is being […] Read More…

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Your Small Business IRS Examination Might Take a Criminal Turn by JONATHAN KALINSKI

If you or your client are under examination by the IRS Small Business/Self-Employed (“SB/SE”) division, changes are your case will not be referred criminally.  Currently, criminal fraud referrals from the IRS civil divisions are only approximately 7% of IRS Criminal Investigations Division’s (“CI”) inventory.  Things, however, are changing, and taxpayers and their representatives should take […] Read More…

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California Doubles Down on Taxing the Underground Economy: What AB 1296 Could Mean for Tax Enforcement by SANDRA R. BROWN and TENZING TUNDEN

California is showing it is serious about taxing the underground economy. On September 13, Assembly Bill 1296 also known as “AB 1296”, was passed with unanimous consent by the California State Senate and California State Assembly.[1] If signed into law, AB 1296 will authorize California tax agencies to exchange intelligence, data, documents, information, complaints, or lead […] Read More…

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Don’t Forget About Making a FOIA Request – by STEVEN TOSCHER and GARY MARKARIAN

A recent report  by  the Treasury Inspector General for Tax Administration (TIGTA)  after an audit into the Internal Revenue Service’s (IRS) denial of Freedom of Information Act (FOIA) requests for the 2018 fiscal year reminds us of the importance of using FOIA in the course of our dealings with the IRS and to not routinely […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to Speak on Tax Treatment of Cryptocurrency Losses Suffered by Individual Taxpayers

We are pleased to announce that Steven Toscher and Michel Stein will be presenting at an upcoming STRAFFORD WEBINAR: Tax Treatment of Cryptocurrency Losses Suffered by Individual Taxpayers.  Thursday, September 12, 2019 from 10:00 a.m. – 11:50 p.m. (PST)/1:00 p.m. to 2:50 p.m. (EDT).  For more information Click Here. Investments in bitcoin and other cryptocurrencies […] Read More…

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STEVEN TOSCHER quoted in Tax Notes “Small Business Enforcement Gets Fresh Focus From New IRS Bosses”

IRS Commissioner Charles Rettig’s commitment to fighting tax fraud seems to have manifesteditself in at least one of his recent personnel moves. Starting September 1, the deputy chief of the Criminal Investigation division, Eric Hylton, will take over as commissioner of the Small Business/Self-Employed Division, and a couple days later, Darren Guillot will move from director of […] Read More…

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STEVEN TOSCHER quoted in Tax Notes “Practitioners Balk at Potential DOJ Willful FBAR Argument”

Practitioners are disturbed by a possible legal stance of the Justice Department in the latest dust-up over foreign bank account reporting, which would negate reliance on a professional as a defense to willful penalties. Tax Notes talked with two practitioners following filings of a joint pretrial statement and proposed jury instructions in Dadurian that seemingly […] Read More…

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The IRS Is Using Its Big Data and Reminds Us and Its Agents That They Have Access to Records of Large Cash Transactions at Financial Institutions By Steven Toscher

The IRS has recently provided interim guidance to clarify actions IRS Examiners musttake to analyze and document Currency Transaction Report (CTR) data during an audit.  The Guidance, which is effective immediately, will be incorporated into IRM 4.10.4, Examination of Returns, Examinations of Income. Prior to incorporation, IRM 4.10.4 provided very little guidance on when and how to […] Read More…

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SANDRA BROWN to speak at the The Cambridge 37th Annual International Symposium on Economic Crime

We are pleased to announce that Sandra R. Brown, along with Chair Ian Comisky, Fox Rothschild and Panelists Don Fort, Chief, Criminal Investigation IRS, Larry Campagna, Chamberlain Hrdlicka, and Caroline Ciraolo, Kostelanetz & Fink, will be speaking on “Cooperation or Compulsion: The Emerging U.S. Experience with Voluntary and Involuntary Disclosures of Foreign Transactions,” at the […] Read More…

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SANDRA BROWN to speak on The Rise of Injunction and Disgorgement Actions under Section 7402 of the Internal Revenue Code

We are pleased to announce that Sandra Brown will be presenting at an upcoming ABA WEBINAR: The Rise of Injunction and Disgorgement Actions under Section 7402 of the Internal Revenue Code.  Thursday, August 15, 2019, 1:00 p.m. EDT/ 10:00 a.m. PST.  For more information Click Here. This webinar explores the current legal and enforcement landscape surrounding […] Read More…

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Cryptocurrency Enforcement is Here by MICHEL STEIN

For those who have failed to report their cryptocurrency transactions correctly — be warned.   The Internal Revenue Service (IRS) is paying attention. IRS Virtual Currency Contact Letters Beginning this month (July 2019), the IRS has begun sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay tax from virtual […] Read More…

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