Our Blog

UCLA 36th Annual Tax Controversy Virtual Institute -October 20, 2020

Please join Sandra R. Brown, former Acting United States Attorney, as she moderates a panel featuring IRS Director of Fraud Enforcement Damon Rowe and IRS CI Special Agent in Charge Ryan Korner, entitled “What Every Practitioner Needs to Know to Protect Their Clients and Themselves From Civil Fraud Penalties and Criminal Investigations”, to be webcast […] Read More…

Read More

STEVEN TOSCHER, DENNIS PEREZ and CORY STIGILE to Speak on High Net Worth Audits

We are pleased to announce that Steven Toscher, Dennis Perez, and Cory Stigile will be speaking at an upcoming Spidell webinar, “High Net Worth Audits” on Wednesday, October 21, 2020, 10:00 a.m. – 12:00 p.m. PST The Global High Wealth Group is an industry group created by the IRS LB&I in 2009. The purpose of the Global […] Read More…

Read More

STEVEN TOSCHER DENNIS PEREZ and MICHEL STEIN to Speak on High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance

We are pleased to announce that Steven Toscher, Dennis Perez and Michel Stein will be speaking at an upcoming Strafford webinar, “High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance” on Thursday, October 22, 2020, 1:00 p.m. – 2:30 p.m. EDT/ 10:00 a.m. – 11:30 a.m. PST The IRS has increased […] Read More…

Read More

What Makes a Failure to File Your Tax Returns a Felony? by SANDRA BROWN

As Benjamin Franklin once wrote, “in this world nothing can be said to be certain, except death and taxes.” For any U.S. citizen or resident with annual income in excess of a statutorily determined amount, the requirement to file a tax return is not only certain, but is a legal obligation. Contrary to popular myth, […] Read More…

Read More

JONATHAN KALINSKI Quoted in in Tax Notes Article Regarding IRS and the Cannabis Industry

IRS attempts to help cannabis industry taxpayers understand their tax obligations likely signal an increased interest in enforcement, according to practitioners. Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes that the information in the FAQ is well known to the state-legal marijuana industry, but “the IRS doesn’t just pop up —even though […] Read More…

Read More

SANDRA BROWN Quoted in in Wonderful LAW360 Article on Justice Ginsburg’s Legacy in Tax Cases

Law360 — Included in Justice Ruth Bader Ginsburg’s monumental legacy are several tax opinions in which she addressed whether a California corporate franchise tax violates the U.S. Constitution, how states can tax citizens and when employment taxes apply to baseball players’ back pay. Justice Ruth Bader Ginsburg in a panel discussion at Georgetown University Law […] Read More…

Read More

STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to Speak on Handling LBI Wealth Squad Examinations and Related IRS Enforcement Issues for High Net Worth Individuals

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CPA Academy webinar on Handling LBI Wealth Squad Examinations and Related IRS Enforcement Issues for High Net Worth individuals  Thursday, September 29, 2020, 9:00 a.m. – 10:30 a.m. (PST). The Global High Wealth Group is an […] Read More…

Read More

STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak on New Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming CPA Academy webinar on New Developments in Cryptocurrency – Reporting and Enforcement, Thursday, September 24, 2020, 2:00 p.m. – 3:00 p.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at […] Read More…

Read More

STEVEN TOSCHER, ROBERT HORWITZ and SANDRA BROWN to Speak on Yes, You Actually Can Go to Jail for Not Paying Taxes

We are pleased to announce that Steven Toscher, Robert Horwitz and Sandra Brown will be speaking at the upcoming CPA Academy webinar on Yes, You Actually Can Go to Jail for Not Paying Taxes, Tuesday, September 22, 2020, 2:00 p.m. to 3:00 p.m. (PST). In recent years, pursuing criminal tax cases involving a taxpayer’s interference […] Read More…

Read More

SANDRA BROWN Quoted in in LAW360 on IRS New Fraud Office

The novel coronavirus pandemic isn’t delaying the rampup of the Internal Revenue Service’s recently launched office to combat tax fraud, the office’s director told Law360 in a recent interview. The former head of the IRS criminal investigation unit is now the director of its new fraud enforcement office. (AP) Though the pandemic has affected the […] Read More…

Read More

STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak on New Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming CalCPA webinar on New Developments in Cryptocurrency – Reporting and Enforcement, Tuesday, September 1, 2020, 9:00 a.m. to 10:30 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance […] Read More…

Read More

Ninth Circuit Holds Annuities from a GRAT Were Includible in the Taxable Estate under Section 2036(a)(1) By: CORY STIGILE and TENZING TUNDEN

In Badgley v. U.S, 957 F.3d 969 (9th Cir. 2020), the9th Circuit addressed the unfortunate fact pattern when a taxpayer dies prior to the termination of a lengthy (15-year) grantor-retained annuity trust (“GRAT”).  As background, GRATs allow a grantor to transfer property to a beneficiary in trust while retaining the right to an annuity for […] Read More…

Read More

Important This site makes use of cookies which may contain tracking information about visitors. By continuing to browse this site you agree to our use of cookies.