TAXLITIGATOR Blog

Steven Toscher to Speak at Upcoming USD- Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind

Steven Toscher to Speak at Upcoming USD- Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind

On my way to Mérida in the Yucatán. Great weather, great food, Mayan ruins and exploration of the intersection of tax fraud and customs fraud with two great panel members, Wazirah Allen, IRS-Criminal Investigations, Director of International Operations and Jeff Neiman, Neiman Mays Floch & Almeida PLLC. Patrick Martin is a great host and thank you University of SanDiego […] Read More…

Read More

The California Supreme Court Says the Only Way to Challenge a Special Assessment of Property Tax is by Exhausting Administrative Remedies by Robert S. Horwitz

The California Supreme Court Says the Only Way to Challenge a Special Assessment of Property Tax is by Exhausting Administrative Remedies by Robert S. Horwitz

In 2008, California enacted the Property Assessed Clean Energy (“PACE”) Act that allows local governments to provide homeowners with financing for energy efficient home improvements. PACE allows local governments to fund their PACE programs by issuing bonds. The special assessment is assessed and collected “in the same manner and at the same time” as local […] Read More…

Read More

Steven Toscher to Speak at Upcoming USD- Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind

Steven Toscher to Speak at Upcoming USD- Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind

We are pleased to announce that Steven Toscher along with Wazirah Allen, IRS-Criminal Investigations, Director of International Operations and Jeffrey Neiman will be speaking at the upcoming University of San Diego School of Law – Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind, February 16-17,2026, at Centro Internacional de […] Read More…

Read More

Sebastian Voth and Philipp Behrendt to Teach through UCLA Extension on Digital Assets Taxation

Sebastian Voth and Philipp Behrendt to Teach through UCLA Extension on Digital Assets Taxation

We’re pleased to announce that Sebastian Voth and Philipp Behrendt will be teaching this online course on Taxation of Digital Assets offered by UCLA Extension from February 10th through March 17th. This online course prepares legal and tax professionals to plan, analyze, and implement compliant reporting for digital-asset transactions under current IRS rules. We concentrate on statutory and regulatory […] Read More…

Read More

Fifth Circuit Hands the Taxpayer a Win in the First Appeals Court Case Interpreting “Limited Partner” for Purposes of Self-Employment Tax by Robert S. Horwitz

Fifth Circuit Hands the Taxpayer a Win in the First Appeals Court Case Interpreting “Limited Partner” for Purposes of Self-Employment Tax by Robert S. Horwitz

Social security and Medicare tax is based on wages paid employees under Internal Revenue Code (IRC) § 3101 and “net earnings from self-employment” under IRC § 1401.  “Net earnings from self-employment” is defined in IRC § 1402 and includes an individual partner’s “distributive share … of income or loss” of the partnership.  Section 1402 contains […] Read More…

Read More

From the Los Angeles Garment District to the Southwest Border to the Most Populous County in Minnesota – How the Treasury Department’s Issuance of Geographic Targeting Orders “Follow the Cash” to Combat Financial Crimes by Sandra R. Brown

From the Los Angeles Garment District to the Southwest Border to the Most Populous County in Minnesota – How the Treasury Department’s Issuance of Geographic Targeting Orders “Follow the Cash” to Combat Financial Crimes by Sandra R. Brown

On January 8, 2026, in response to alleged benefits fraud in Minnesota, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced the issuance of a Geographic Targeting Order (GTO) requiring all banks and money transmitters located in Hennepin County and Ramsey County, Minnesota, (Covered Businesses) to file reports with FinCEN of certain international fund transfers […] Read More…

Read More

Jonathan Kalinski and Melissa Briggs Elected Fellows American College of Tax Counsel

Jonathan Kalinski and Melissa Briggs Elected Fellows American College of Tax Counsel

We are pleased to announce that Jonathan Kalinski and Melissa Briggs have been elected Fellows of the American College of Tax Counsel. Jonathan and Melissa join eight other members of our firm who are Fellows of the most prestigious group of tax lawyers in the United States. The President of ACTC welcomed the new Fellows, noting that […] Read More…

Read More

Evan Davis Recognized by Legal 500 City Elite: White Collar Crime

Evan Davis Recognized by Legal 500 City Elite: White Collar Crime

We are proud to announce that Evan Davis, a former white-collar federal prosecutor and current Principal of our firm, has been named to the inaugural list of Legal 500 City Elite’s top white-collar lawyers in Los Angeles. “US Elite emphasizes lawyers who are handling work at the top of the legal market in their respective […] Read More…

Read More

USC Gould School of Law 2026 Tax Institute – January 26-28, 2026

USC Gould School of Law 2026 Tax Institute – January 26-28, 2026

As a member of the Planning Committee for the 2026 Tax Institute, hosted by USC Gould School of Law, I am excited to remind all that the Institute is taking place January 26–28, 2026, in Los Angeles and online. This year’s program features three days of advanced tax programming across corporate, partnership, real estate, individual, enforcement, […] Read More…

Read More

Philipp Behrendt Promoted to Principal

Philipp Behrendt Promoted to Principal

Hochman Salkin Toscher Perez P.C. is pleased to announce that Philipp Behrendt has been promoted to Principal. Before relocating to the United States, Philipp practiced as a tax lawyer in Germany for more than five years. He joined our firm four years ago and has built a practice focused on high-stakes tax controversy and examinations, […] Read More…

Read More

ABA Tax Section 2026 Midyear Tax Meeting

ABA Tax Section 2026 Midyear Tax Meeting

We are pleased to announce that four of our attorneys will be speaking at the upcoming ABA Tax Section 2026 Midyear Tax Meeting, January 15-17, 2026 at the Marriott Marquis San Diego Marina on the following key topics: Michel R. Stein, along with Jeff Oliver, Plante Moran, Rob Kovacev, Miller & Chevalier, and Alexandra Minkovich, […] Read More…

Read More

Michel R. Stein and Philipp Behrendt to Speak at Upcoming CalCPA Webinar on Cryptocurrency Tax Compliance

Michel R. Stein and Philipp Behrendt to Speak at Upcoming CalCPA Webinar on Cryptocurrency Tax Compliance

We are pleased to announce that Michel R. Stein and Philipp Behrendt will be speaking at the upcoming CalCPA webinar on Cryptocurrency Tax Compliance: Tax Filing Requirements, New Form 1099-DA Broker Reporting Rules, and Managing IRS Examinations, on Tuesday, January 13, 2026, 9:00 a.m. – 10:30 a.m. (PST). The program will provide a practical roadmap […] Read More…

Read More
Warning