TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 14, 2022

Philipp Behrendt is a graduate of University of Southern California (USC) Gould School of Law (LL.M.) and a former associate of the leading German tax firm Flick Gocke Schamburg. Philipp’s prior experience includes representing wealthy individuals and companies in global tax settings, cross-border investigations and audit matters, as well as tax compliance issues arising from […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 11, 2022

We are pleased to announce that Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming Lorman Educational Services Webinar on Form 8300 Reporting Requirements, Wednesday February 23, 2022, 10:00 a.m. – 11:40 a.m. (PST). The law requires that trades and businesses report cash payments of more than $10,000 to the federal government by filing Form […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, January 31, 2022

We are pleased to announce that Steven Toscher will be speaking at the upcoming Florida Tax Institute on Audits and Tax Controversy, Thursday February 3, 2022, 10:00 a.m. – 11:30 a.m. (EST). The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions.  The reviews are expected to include […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, January 29, 2022

We are pleased to announce that Sandra R. Brown will be presenting at the upcoming American Bar Association Virtual 2022 Midyear Tax Meeting, Tuesday, February 1, 2022, 2:30 p.m. – 3:00 p.m. (ET).  Sandra will provide updates on “Important Criminal Developments” on behalf of the Tax Section’s Civil and Criminal Tax Penalties (CCTP) Sentencing Subcommittee.   […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, January 13, 2022

The dirty little secret, that isn’t so secret after the release of the Pandora Papers (Pandora Papers – ICIJ), is that the United States is a tax and money-laundering haven for much of the world because, unlike most countries, many U.S. states allow persons to own entities without revealing their ownership to authorities.  Last month, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, January 06, 2022

Please join us January 24-26, 2022 for the USC Gould School of Law 2022Tax Institute virtual event. Meet with fellow tax professionals and address the cutting-edge tax issues affecting the industry. This three-day institute includes discussions, networking opportunities, breakout sessions and workshops led by heavy hitters in the field. We have an excellent line up of programs – […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, January 05, 2022

We are pleased to announce that Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming Strafford Webinar on Tax Reporting of Cryptocurrency: Calculating Basis, Income, and Gain, Thursday, January 20, 2022, 10:00 a.m. – 11:50 a.m. (PST). This course will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, December 21, 2021

I previously blogged on the Ninth Circuit’s decision in United States v. Boyle, 991 F.3d 1077 (2021), where the Court held the $10,000 non-willful FBAR penalty applies on a per-form rather than per-account basis.  Several district courts had reached the same conclusion, including the district court in United States v. Bittner, 469 F.Supp.3d 709 (ED […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, December 17, 2021

The IRS is getting more information from its cryptocurrency exchange John Doe summonses, which it will use to fuel another round of soft letters to account holders, according to an agency official. Michel R. Stein of Hochman Salkin Toscher Perez PC noted that the Coinbase summons used older tax years but the same dollar threshold […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, November 30, 2021

We are pleased to announce that Sandra Brown along with Sharyn Fisk, IRS Office of Professional Responsibility, Caroline D. Ciraolo, and Bradley M. Seltzer will be speaking at the upcoming PLI Institute Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021 LA webinar, on “Balancing Tax Planning, Advocacy and Professional Ethics: The Rules That Every Tax Advisor […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, November 29, 2021

We are pleased to announce that Steven Toscher along with Larry Campagna, Honorable Elizabeth Copland and Charles Muller III will be speaking at the upcoming University of Texas 69th Annual Taxation Conference webinar, on “What Does Enforcement Look Like Today?” on Thursday December 2, 2021, 1:30 p.m. – 3:00 p.m.(CST). While Congress debates whether to fund more IRS enforcement, the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, November 15, 2021

We are pleased to announce that Sandra Brown will be speaking at the upcoming Freeman Law International Tax Symposium webinar, on “International Criminal Tax” on Friday, November 19, 2021, 9:25 a.m. – 10:15 a.m. (CST). The United States and other countries have increased focus on investigating and prosecuting international tax crimes.  With the rise of […] Read More…