TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 24, 2025

We are pleased to announce that four of our Principals will be presenting at the ABA 2025 Midyear Tax Meeting which will take place on February 19-21 at the JW Marriott Los Angeles L.A. LIVE. Learn from and meet with the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, January 23, 2025

We previously wrote about the IRS’s campaign under its Large Business & International (LB&I) Division: The Business Aircraft Campaign (the “BAC” or “aircraft campaign”). The purpose of this article is to further delve into some nuances associated with the aircraft campaign while also considering likely tax implications for high-income individuals who have claimed aircraft-related expenses. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, January 23, 2025

We are pleased to announce that Michel R. Stein along with Charles M. Ruchelman (Caplin & Drysdale) and Fred Murray (Office of Chief Counsel, Internal Revenue Service) will be speaking at the upcoming Florida Tax Institute at the JW Marriott Tampa Water Street on Recent Developments in Tax Court Litigation – What You Need to Know webinar, Thursday, February […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, January 18, 2025

The Internal Revenue Service (IRS) recently issued Notice 2025-7 on December 31, 2024, providing temporary relief for taxpayers who sell, dispose of, or transfer digital assets held in the custody of brokers. This notice addresses challenges taxpayers face in adequately identifying specific units of digital assets during sales, dispositions, or transfers, particularly when brokers lack […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, January 13, 2025

Hochman Salkin Toscher Perez P.C. is pleased to announce that Melissa Briggs has joined our firm as a Principal.  Ms. Briggs joins us as a former Assistant United States Attorney for the United States Attorney’s Office for the Central District of California, Tax Division and a former U.S. Department of Justice, Tax Division Appellate Attorney. During her […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 03, 2025

On December 23, 2024, the U.S. District Court for the Southern District of New York authorized the IRS to issue “John Doe” summonses targeting individuals who may have used the services of Trident Trust Group (“Trident”) or related entities to conceal foreign assets or income. This order marks the continued efforts in the IRS’s campaign […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, January 02, 2025

In a recent Tax Notes article by Mary Katherine Browne (published December 31, 2024), the spotlight is on the cryptocurrency industry’s legal challenge to the IRS’s newly finalized decentralized finance (DeFi) broker reporting regulations. The article, titled “Crypto Industry Seeks to Strike Down DeFi Reporting Regs,” delves into the case of Blockchain Association v. IRS, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, December 31, 2024

We are pleased to announce that Dennis Perez, Michel R. Stein and Robert S. Horwitz will be speaking at the upcoming CalCPA Federal and State Residency Issues webinar, Tuesday, January 14, 2025, 9:00 a.m. – 10:30 a.m. (PST). This webinar will guide tax professionals and advisers on the latest IRS examination guidance on U.S. residency and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 30, 2024

We are pleased to announce that the USC Gould School of Law 2025 Tax Institute will take place on January 27-29 at the Sheraton Grand Hotel, Los Angeles. We have an exceptional line up of speakers and topics this year. The three day Institute covers the most important topics in taxation including corporate, partnership, and estate planning. Additionally, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, December 27, 2024

In a milestone for cryptocurrency taxation, the recent federal sentencing of Frank Richard Ahlgren III for charges involving the willfully filing of a false tax return marks a pivotal moment in legal-source cryptocurrency income tax enforcement. Hochman Salkin Toscher Perez PC attorneys Sandra R. Brown and Philipp Behrendt shared their insights with Tax Notes, underscoring […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, December 26, 2024

We are pleased to announce that Cory Stigile along with Ellen Swain (Franchise Tax Board) and Oksana Jaffe (KPMG LLP) will be speaking at the upcoming Beverly Hills Bar Association Apportioning of Income for Nonresident Individuals webinar, Tuesday, January 7, 2025, 12:20 p.m. – 1:30 p.m. (PST). This session will provide a substantive analysis of California’s […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 23, 2024

We have the privilege of supporting charitable organizations throughout the year, particularly during the holiday season when needs are even greater. This holiday season, we are committed to giving back to our community by supporting five nonprofit organizations that are improving the world around us, from helping individuals, families and other challenges faced by those […] Read More…