Our Blog

DOJ’s Tax Division Updates Criminal Tax Manual to Address Marinello’s Impact on Charging Decisions – by SANDRA R. BROWN and GARY MARKARIAN

On March 21, 2018, the Supreme Court issued its much awaited decision in Marinello, and in doing so, imposed significant limitations on the government’s ability to bring obstruction charges in tax cases under the so-called Omnibus Clause of 26 U.S.C. § 7202(a).  Since that time, tax practitioners have been watching to see how impactful the […] Read More…

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DENNIS PEREZ, MICHEL STEIN and JONATHAN KALINSKI to Speak on Resolving Employment Tax Disputes

We are pleased to announce that three of our principals Dennis Perez, Michel Stein and Jonathan Kalinski will be speaking at the upcoming CPAacademy webinar on Resolving Employment Tax Disputes Thursday, July 23, 2020, 1:00 pm PST. The IRS is increasing both civil and criminal enforcement against taxpayers who fail to comply with withholding and […] Read More…

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STEVEN TOSCHER to Moderate and Speak at the Upcoming Fifth Annual USD School of Law – RJS Law Tax Controversy Institute (Update)

Hope everybody is having a good weekend and staying safe.  I wanted to send out a reminder for the upcoming University of San Diego School of Law – RJS Law Tax Controversy Institute on Friday, July 17, 2020, from 10:30 am to 2:45 p.m. (PST). This year the program will be a webinar and will be complimentary for […] Read More…

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Fifth Circuit Rules Virtual Currency Transactions and Records Held By Exchanges Do Not Have Fourth Amendment Protections from Search and Seizure by the Government By: SANDRA R. BROWN and TENZING TUNDEN

The IRS had not been shy about highlighting that taxpayers need to report any and all virtual currency transactions appropriately and that it will use its enforcement tools to ensure such compliance.[i]  The IRS’s data-gathering efforts are part of those enforcement tools.   In 2017, the Government used a John Doe Summons to obtain a judicial […] Read More…

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MICHEL STEIN to Speak at the Upcoming STEP LA Webinar on PPP Program Loans

We are pleased to announce that Michel Stein will be speaking at the STEP LA Webinar–Payroll Protection Program Loans: Calculating the Loan Forgiveness Amount, Analysis of Legal Risks of Certifications, Representations in Applicants and Loan Documents, Tax Treatment, SBA Audit Risks, Appeals and Criminal Exposures — on Tuesday, July 14th from 7:30 a.m. – 9:30 […] Read More…

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Court Update: Day Late and a (Million) Dollar(s) Short by JONATHAN KALINSKI

On the eve of filings lawyers often stay awake at night hoping everything goes right.  Occasionally something goes wrong, you just hope it doesn’t happen to you.  Add one more horror story to the list.  In a harsh result, the Ninth Circuit held that the Tax Court correctly dismissed as untimely Organic Cannabis Foundation’s petition.[1] […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and JONATHAN KALINSKI to speak on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques (Discounted Price)

We are pleased to announce that Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the Spidell Webinar–Taxation of Cannabis— on Thursday July 9th  at 10:00 a.m. – 12:00 p.m.  The cannabis business has been growing at very fast pace in California and other jurisdictions since legislative changes legalizing and regulating the sale, […] Read More…

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High Wealth Enforcement is Coming-Get Ready By: STEVEN TOSCHER and TENZING TUNDEN

The moratorium on IRS investigations and collections set forth by the People First Initiative will be ending soon on July 15.[i]  and very high wealth taxpayers should get ready for a little attention from the IRS.  If the moratorium is not extended, the IRS is poised to start the examination of several hundred high net […] Read More…

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SANDRA BROWN to Speak at the Upcoming ABA Virtual 2020 May Tax Meeting

We are pleased to announce that Sandra Brown will be speaking at the ABA Virtual 2020 May Meeting –When You Need to Disclose More Than Just a Tax Crime — on Tuesday July 14th at 2:00 p.m. – 3:00 p.m. (EST). Under the IRS voluntary disclosure practice, in exchange for a timely, accurate, and complete […] Read More…

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IRS Will Now Allow Taxpayers to E-File Amended Returns Due to COVID-19 By ROBERT HORWITZ and TENZING TUNDEN

For taxpayers heading into the extended tax season there is good news! The IRS will now allow E-filing of amended returns. The IRS published a notice on May 28, 2020 that amended returns for tax years beginning on or after January 1, 2017 can be filed electronically.[i]  Previously, amended returns had to be submitted manually […] Read More…

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Watch Out For Increased Tax Enforcement to Battle COVID-19—Good Idea or Money Grab? By STEVEN TOSCHER and TENZING TUNDEN © 2020

The Independent Commission for the Reform of International Corporate Taxation (“Commission”) is a group of leaders from around the world who believe that there is both an urgent need and an unprecedent opportunity to bring about significant reform of the international corporate taxation system.  The Commission is comprised of influential members from parliament, the United […] Read More…

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California Worker Classification Fight Continues But Expect Enforcement by JONATHAN KALINSKI

COVID-19 has placed much of our normal activities on hold.  It hasn’t, however, slowed down the maneuverings around California’s new worker classification law, known as AB5, which took effect January 1, 2020.  Just before the law took effect, the trucking industry won a major victory when Judge Benitez of the Southern District of California issued […] Read More…

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