TAXLITIGATOR Blog

American Families Plan Tax Compliance Agenda By STEVE TOSCHER and SANDRA BROWN

American Families Plan Tax Compliance Agenda By STEVE TOSCHER and SANDRA BROWN

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…

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An LLC “Doing Business” in California by GARY MARKARIAN and ROBERT HORWITZ

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…

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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak at Upcoming Webinar on Partnership Examinations: What You Need To Know About New Partnership Rules

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar, “Partnership Examinations: What You Need to Know About New Partnership Rules” on Tuesday, July 27, 2021, 9:00 a.m. – 10:00 a.m. (PST). This webinar will cover practical considerations for partners and advisers to partnerships now operating under the new partnership […] Read More…

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DENNIS PEREZ AND MICHEL STEIN to Speak at Upcoming Webinar on Tax Practice and Procedures Update: Laws and Lessons Learned

We are pleased to announce that Dennis Perez and Michel Stein will be speaking at the upcoming CalCPA webinar, Tax Practice and Procedures Update: Laws and Lessons Learned” on Monday, July 28, 2021, 1:00 p.m. – 2:30 p.m. (PST). Dennis and Michel will be speaking on important practice and procedural issues facing practitioners, including IRS priorities and the new emphasis on […] Read More…

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Ninth Circuit Reverses Tax Court, Says Form Is More Important than Substance Where Congress Says So by ROBERT S. HORWITZ

It was refreshing to read a Ninth Circuit decision that states in its opening paragraph that “the Tax Court erred by invoking substance-over-form principles to effectively reverse that Congressional judgment and disallow what the statute plainly allowed.”  The decision is Mazzei v. Commissioner, 998 F.3d 1041 (9th Cir. 2021), rev’g 150 T.C. 138 (2018).  The […] Read More…

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The Long Arm of FBAR Enforcement and Collection by STEVEN TOSCHER, SANDRA BROWN and GARY MARKARIAN

Background Last year, our partner, Robert Horwitz, blogged about United States v. Schwarzbaum[1], and detailed Mr. Schwarzbaum’s willful failure to file FBARs for his Swiss and Costa Rican offshore bank accounts.[2] The Court in that case entered a judgment against Mr. Schwarzbaum of approximately $15.8 million in FBAR penalties, interest, and late-payment penalties. This blog […] Read More…

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MICHEL STEIN and SANDRA BROWN to Speak at Upcoming Webinar on IRS Promoter Investigations, Enforcement Actions, and Penalties: Syndicated Conservation Easements, Micro-Captives

We are pleased to announce that Michel Stein, Sandra Brown along with Lois Dietrich will be speaking at the upcoming Strafford webinar, “IRS Promoter Investigations, Enforcement Actions, and Penalties: Syndicated Conservation Easements, Micro-Captives” on Tuesday, July 20, 2021, 10:00 a.m. – 11:30 a.m. (PST). This CLE/CPE webinar will guide tax professionals through new IRS enforcement actions focused on promoters of syndicated […] Read More…

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Death and the Non-Willful FBAR Penalty by ROBERT HORWITZ

Causes of action based on penal statutes do not survive the defendant’s death while those based on remedial statutes survive death.  In this context, a remedial statute is one meant to compensate the victim for a harm suffered, while a penal statute is meant to impose damages upon a defendant for a general wrong.  Given […] Read More…

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SANDRA BROWN and STEVEN TOSCHER to Speak at Upcoming Webinar on The IRS New Office of Fraud Enforcement What Practitioners Can Expect, the Consequences and Best Practices

We are pleased to announce that Sandra Brown and Steven Toscher along with Marty Schainbaum, Damon Rowe, and Richard Hassebrockwill be speaking at the upcoming USD Sixth Annual USD School of Law – RJS Law Tax Controversy Institute webinar, “The IRS New Office of Fraud Enforcement—What Practitioners Can Expect, the Consequences and Best Practices” on Friday, July 16, 2021, […] Read More…

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STEVEN TOSCHER Quoted in New Republic article on how The IRS Can Be a Force for Social Good.

On June 10, 2019, John Lewis took to the floor of the House of Representatives to tout public to know it. “This is not a Republican or a Democratic bill,” Lewis said. “It is an American one,” a vital effort to reinvigorate a failing government agency. If all else fails, Biden may be able to […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to Speak at Upcoming Webinar on Handling the New IRS Global High Wealth Examinations

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CalCPA webinar, “Handling the New IRS Global High Wealth Examinations” on Tuesday, June 29, 2021, 9:00 a.m. – 10:00 a.m. (PST). The Global High Wealth Group is an industry group created by the IRS LB&I in […] Read More…

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Treating an Employee as an Independent Contractor Can Lead to a Fraud Penalty by ROBERT HORWITZ

Ron Bell was an engineer who earned an MBA and went into finance.  After a number of years working for various financial firms, he set up his own company, Bell Capital Management, Inc. (“BCM”), in Atlanta, Georgia, to provide investment services and financial planning for clients.  He was quite successful.  From BCM’s founding throughout its […] Read More…

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