Our Blog

The Supreme Court Bids Bob Richards Adieu, Limiting the Role of Federal Common Law by ROBERT S. HORWITZ

Section 1501 of the Internal Revenue Code allows a parent corporation and its subsidiaries to file a consolidated return that effectively treats the consolidated group as one entity for tax purposes.  The IRS has issued detailed regulations concerning consolidated groups.  It has not issued any regulations on how refunds to a consolidated group are to […] Read More…

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IRS Takes Next Step in Enhancing its Criminal Fraud Referral Program By STEVEN TOSCHER and SANDRA R. BROWN

The Internal Revenue Service (“IRS”)  took a major step in enhancing its criminal fraud referral program by announcing a national coordinator who will oversee fraud referrals from all of the operating divisions.  Damon Rowe, formally the Executive Director of International Operations for IRS Criminal Investigations and former Special Agent in Charge of the Los Angeles […] Read More…

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DENNIS PEREZ, MICHEL STEIN and JONATHAN KALINSKI to speak on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers

We are pleased to announce that three of our principals Dennis Perez, Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Adviser, Tuesday, March 31, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. The IRS is forceful in its efforts to pursue taxpayers […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to speak on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives

We are pleased to announce that three of our principals Steven Toscher and Michel Stein will be speaking at the upcoming Strafford webinar on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives, Tuesday, May 26, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. All tax practitioners need to be up-to-date on the […] Read More…

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AVRAM SALKIN, STEVEN TOSCHER and MICHEL STEIN to speak on Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easement Transactions

We are pleased to announce that three of our principals Avram Salkin, Steven Toscher, and Michel Stein will be speaking at the upcoming Strafford webinar on Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easement Transactions, Tuesday, May 5, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. The IRS recently announced a significant increase in enforcement actions […] Read More…

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MICHEL STEIN and JONATHAN KALINSKI to speak on Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471

We are pleased to announce that three of our principals Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471, Thursday April 30, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. Cross-border tax audits are expanding dramatically, and the resulting tax assessments […] Read More…

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MICHEL STEIN, JONATHAN KALINSKI and ROBERT HORWITZ to speak on Partnership Audit Adjustments Under the Centralized Audit Regime

We are pleased to announce that three of our principals Michel Stein, Robert Horwitz, and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Partnership Audit Adjustments Under the Centralized Audit Regime, Wednesday, April 22, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. The centralized partnership audit regime (CAR) is effective now. The Bipartisan Budget […] Read More…

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If the Court Thinks You Preferred a “Lavish Lifestyle” Over Paying Taxes, You May Find the Tax Not Dischargeable in Bankruptcy (Unless You Live in the Ninth Circuit) by ROBERT S. HORWITZ

I recently blogged on the Eleventh Circuit’s decision in In re Shek rejecting First, Fifth and Tenth Circuit precedent that a late return filed two years or more before bankruptcy is not discharged.  Today I am blogging on another recent bankruptcy case, In re Harold, 2020 WL 709866 (B. Ct. M.D. Mich. 2/12/2020), which addressed […] Read More…

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High Income Non-Filers Are Back in Sights of the New Enforcement Minded IRS – by STEVEN TOSCHER and GARY MARKARIAN

On February 19, 2020, the IRS issued IR-2020-34, which states the IRS “will step up efforts to visit high-income taxpayers who in prior years have failed to timely file one or more of their tax returns.”  If the Commissioner of Internal Revenue Charles P. Rettig was speaking, he might say that high income taxpayers who […] Read More…

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Eleventh Circuit Creates Split in the Circuits on Issue of Whether a Later Return is a Return for Purposes of the Bankruptcy Code by ROBERT S. HORWITZ

Three types of tax debts are excepted from discharge in bankruptcy: First, those entitled to priority under sec. 507(a) of the Bankruptcy Code.  11 U.S.C. Sec. 523(a)(1)(A). Second, those with respect to which a return, if required, was not filed or was filed after it was last due and after two years before the date […] Read More…

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MICHEL STEIN to speak on Update on the Taxation of Cryptocurrency Transactions

We are pleased to announce that Michel Stein will be speaking at the upcoming SFVBA Taxation Law Section Seminar on Update on the Taxation of Cryptocurrency Transactions, Tuesday, February 18, 2020, 12:00 pm-1:15 pm. Mr. Stein will discuss new IRS pronouncement and recent developments regarding taxation of cryptocurrency transaction For full programming details Click Here.   […] Read More…

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American College of Tax Counsel Elects New Fellow MICHEL STEIN

We are pleased to announce that Michel Stein has been elected as Fellow by the American College of Tax Counsel. Michel, a principal of our firm, joined us in 1998, after a prestigious position as an Attorney-Advisor at the United States Tax Court. He holds an LL.M in Taxation from New York University and is a former Chair […] Read More…

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