TAXLITIGATOR Blog

SANDRA BROWN to Speak at Upcoming Webinar on Practitioners Guide to IRS High Income/High Wealth Audits

We are pleased to announce that Sandra Brown along with John Colvin, Monique (Mimi) R. Gabel, Sarah E. Paul and Cliff Scherwinski will be speaking at the upcoming ABA Section of Real Property, Trust & Estate Law eCLE webinar, “Practitioners Guide to IRS High Income/High Wealth Audits” on Wednesday, September 15, 2021, 10:00 a.m. – 11:30 a.m. (PST) | 1:00 p.m. […] 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, and Sandra Brown along with Lois Dietrich, the Acting Director of the IRS’s Office of Promoter Investigations, will be speaking at the upcoming Strafford webinar, “IRS Promoter Investigations, Enforcement Actions, and Penalties: Syndicated Conservation Easements, Micro-Captives” on Tuesday, September 14, 2021, 10:00 a.m. – 11:30 a.m. (PST). This CLE/CPE webinar will guide tax professionals […] Read More…

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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak at Upcoming Webinar on Partnership Audit Procedures for Tax Counsel

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming CSTC webinar, “Partnership Audit Procedures for Tax Counsel” on Tuesday, September 1, 2021, 10:00 a.m. – 11:40 a.m. (PST). The IRS Large Business and International Division stated in its most recent Focus Guide that an increase […] Read More…

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DENNIS PEREZ, MICHEL STEIN and JONATHAN KALINSKI to Speak at Upcoming Webinar on Employment Tax Matters: Worker Classification and AB5

We are pleased to announce that Dennis Perez, Michel Stein and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar, “Employment Tax Matters: Worker Classification and AB5″” on Tuesday, August 31, 2021, 9:00 a.m. – 10:00 a.m. (PST). The IRS increases both civil and criminal enforcement against taxpayers who fail to comply with withholding […] Read More…

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Watch Out Crypto Exchanges and Hodlers! JONATHAN KALINSKI Quoted in Tax Notes Article

At a recent Stafford webinar on NFTs, Jonathan Kalinski of Hochman Salkin Toscher Perez PC advised practitioners to be cautious in their positions. Just because there is no law on a new cryptoasset question doesn’t mean that the IRS can’t argue that “you should have known better” down the road. Crypto audits are ramping up, […] Read More…

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John Who? The IRS’s Increasing Use of John Doe Summonses to Gather Data and Close the Tax Gap By: SANDRA BROWN

On July 28, 2021, the Internal Revenue Service (IRS) and the Department of Justice (DOJ) announced that it had obtained a Court Order authorizing summonses for records relating to U.S. Taxpayers who used Panama Offshore Service Providers (POLS) to hide assets and evade taxes.[i]   The issuance of these “John Doe” summonses will permit the IRS […] Read More…

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SAVE THE DATE – ABA – 38th Annual Institute on Criminal Tax Fraud – December 8-10, 2021

We are pleased to welcome everyone back to an in person meeting for the ABA 38th National Institute on Criminal Tax Fraud and Eleventh Civil Tax Controversy which will again take place in Las Vegas Nevada on December 8-10. We are all looking forward to getting together and continuing the long tradition of outstanding panelists and government […] Read More…

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JONATHAN KALINSKI to Speak at Upcoming Webinar on Tax Treatment of Non-Fungible Tokens: Applicable Tax Rules, Characterization Issues, Crypto Transactions

We are pleased to announce that Jonathan Kalinski along with Jordan Bass will be speaking at the upcoming Strafford webinar, “Tax Treatment of Non-Fungible Tokens: Applicable Tax Rules, Characterization Issues, Crypto Transactions” on Tuesday, August 10, 2021, 10:00 a.m. – 11:30 a.m. (PST). This CLE/CPE webinar will provide tax counsel, accountants, and other advisers with […] Read More…

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SAVE THE DATE – UCLA – 37th Annual Tax Controversy Institute – October 21, 2021

We are pleased to welcome everyone back to an in person meeting for the 37th UCLA Extension Tax Controversy Institute which will be on held on October 21st, at the Beverly Hills Hotel in Beverly Hills, California. We have another great line up of esteemed panelists and government speakers who will presenting on a full […] Read More…

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Is there a Ray of Light in Willful FBAR Cases, or Am I Just a Cockeyed Optimist? by ROBERT S. HORWITZ

The Second Circuit recently joined the Fourth (United States v. Horowitz), Eleventh (United States v. Rum) and Federal Circuits (Norman v. United States) in holding that the 1987 regulation setting the maximum penalty for willful FBAR violations at $100,000 was invalid due to the 2004 statutory amendment that provides that Treasury may impose a maximum […] Read More…

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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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