The views: Steve Toscher (Managing Principal, Hochman Salkin Toscher Perez) and Stuart Gibson (Chief Editor, Global News and US, IBFD) discuss the main tax issues you should be aware of regarding virtual currency. They summarize the IRS’s public guidance on virtual currency, efforts within the United States to advise taxpayers of their reporting obligations, as […] Read More…
Read MoreWe are pleased to announce that Steven Toscher will be moderating and Evan Davis will be speaking at the upcoming ABA webinar, “A New Regime of Transparency: Anti-Money Laundering and Corporate Transparency Acts of 2020 and Expansion of Cryptocurrency Reporting” on Tuesday, April 27, 2021, 1:00 p.m. (EST), 10:00 a.m. (PST).Joining the panel will be Andrew Winerman, Acting Deputy Associate Director of […] Read More…
Read MoreWhat does the title of one of Sergio Leone’s great Clint Eastwood westerns have to do with Foreign Bank Account Reports (known in the trade as “FBARS”) and FBAR penalties. Two significant court of appeal opinions and a district court opinion involving the FBAR penalty were issued recently (United States v. Boyd, __ F.3d __, […] Read More…
Read More“When a man’s got money in his pocket he begins to appreciate peace.” The Man With No Name Why start with a quote from one of Sergio Leone’s great Clint Eastwood westerns, A Fistful of Dollars. It is more peaceful to have money in your pocket, or at least close by in a domestic financial […] Read More…
Read MoreIn the Lord of the Rings saga, the antagonist is a disembodied entity called Sauron who was represented by a flame-filled “Great Eye.” Sauron’s Great Eye had powerful vision when fixed upon his rivals, but even this powerful eye was unable to see unaided into the thoughts of humans. Fans of the LOTR movies know […] Read More…
Read MoreOn March 30, the Department of Justice, Tax Division, filed a petition for leave to serve a “John Doe” summons on Payward Ventures, also known as “Kraken,” requesting account information for all United States taxpayers who held accounts there with the equivalent value of $20,000 or more in cryptocurrency for any one year from 2016 […] Read More…
Read MoreWe are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Strafford webinar, “Cryptocurrency Tax Compliance in the Post-$50,000 Bitcoin World: Tax Filing Requirements, Managing IRS Examinations” on Thursday, April 22, 2021, 10:00 a.m. – 11:30 a.m. (PST), 1:00 p.m. – 2:30 p.m. (EST). This CLE/CPE webinar […] Read More…
Read MoreWe are very pleased to announce that Sandra Brown is featured in this month’s Los Angeles Lawyer discussing the IRS Voluntary Disclosure Practice. Check out the current state of the practice and Sandra’s insights. The tax system of the United States is often described as one of “voluntary compliance.” However, there is little about the […] Read More…
Read MoreThe Internal Revenue Service will continue its focus on collecting delinquent taxes from the wealthiest taxpayers. The Treasury Inspector General for Tax Administration (TIGTA) recently published a report on the IRS efforts to collect delinquent taxes from wealthy taxpayers. This is the second report by TIGTA on the IRS attempts to increase compliance of this […] Read More…
Read MoreWe are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Spidell webinar, “Handling Partnership Examinations” on Thursday, March 25, 2021, 10:00 a.m. – 12:00 p.m. (PST). This webinar will cover practical considerations for partners and advisers to partnerships now operating under the new partnership audit regime. […] Read More…
Read More“Friend of the JTPP, Robert S. Horowitz shares an update on penalties in The News from the FBAR Front Isn’t All Bad, It Only Seems That Way Sometimes. It’s good to hear the phrase “non-willful FBAR cases” even if it is a rare case. It seemed for a while that IRS wasn’t able to find […] Read More…
Read MoreThe IRS Criminal Investigation division isn’t focusing its enforcement efforts specifically on cannabis businesses, but is instead treating them like any other cash-intensive business, according to a division official. Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes in part that “. . . practitioners with cannabis clients might need to keep a […] Read More…
Read More