TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, September 23, 2020

Law360 — Included in Justice Ruth Bader Ginsburg’s monumental legacy are several tax opinions in which she addressed whether a California corporate franchise tax violates the U.S. Constitution, how states can tax citizens and when employment taxes apply to baseball players’ back pay. Justice Ruth Bader Ginsburg in a panel discussion at Georgetown University Law […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, September 17, 2020

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CPA Academy webinar on Handling LBI Wealth Squad Examinations and Related IRS Enforcement Issues for High Net Worth individuals  Thursday, September 29, 2020, 9:00 a.m. – 10:30 a.m. (PST). The Global High Wealth Group is an […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 14, 2020

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming CPA Academy webinar on New Developments in Cryptocurrency – Reporting and Enforcement, Thursday, September 24, 2020, 2:00 p.m. – 3:00 p.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 14, 2020

We are pleased to announce that Steven Toscher, Robert Horwitz and Sandra Brown will be speaking at the upcoming CPA Academy webinar on Yes, You Actually Can Go to Jail for Not Paying Taxes, Tuesday, September 22, 2020, 2:00 p.m. to 3:00 p.m. (PST). In recent years, pursuing criminal tax cases involving a taxpayer’s interference […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 28, 2020

The novel coronavirus pandemic isn’t delaying the rampup of the Internal Revenue Service’s recently launched office to combat tax fraud, the office’s director told Law360 in a recent interview. The former head of the IRS criminal investigation unit is now the director of its new fraud enforcement office. (AP) Though the pandemic has affected the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 13, 2020

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming CalCPA webinar on New Developments in Cryptocurrency – Reporting and Enforcement, Tuesday, September 1, 2020, 9:00 a.m. to 10:30 a.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 07, 2020

In Badgley v. U.S, 957 F.3d 969 (9th Cir. 2020), the9th Circuit addressed the unfortunate fact pattern when a taxpayer dies prior to the termination of a lengthy (15-year) grantor-retained annuity trust (“GRAT”).  As background, GRATs allow a grantor to transfer property to a beneficiary in trust while retaining the right to an annuity for […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 30, 2020

Under the People First Initiative, the IRS asserted it would generally not start new examinations, except for situations with short statutes of limitations.  As the relief provisions of the People First Initiative waned after July 15, 2020, the IRS has resumed collection activities in earnest, and presumably will also begin new examinations.  The IRS has […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 28, 2020

For years, Beck Asset Management ($26M in AUM) in Zurich has made an unusual disclosure in its Form ADV out “of an abundance of caution.” The firm’s latest Form ADV reveals that “Josef Beck works as Investment Advisor for Beck Verwaltungen AG (“BVAG”), an entity that is under common control with Beck AM only because […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 28, 2020

We are pleased to announce that Jonathan Kalinski will be speaking at the upcoming LawPracticeCLE webinar on Anatomy of a Tax Court Case, Friday, August 7, 2020, 2:00 p.m. – 4:00 p.m. (EST), 11:00 a.m. – 1:00 p.m. (PST). Everything you need to know about navigating the complex world of Tax Court litigation. The discussion […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 23, 2020

We are pleased to announce that Steven Toscher and Jonathan Kalinski will be speaking at the upcoming CalCPA Cannabis Industry Virtual Symposium webinar on Criminal Tax Issues/Going Through an IRS Audit, Friday, August 7, 2020, 1:45 p.m. COVID-19 has wreaked havoc on the economy, and the cannabis sector was not immune. Supply chains and distribution were disrupted, revenues were […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 21, 2020

On March 21, 2018, the Supreme Court issued its much awaited decision in Marinello, and in doing so, imposed significant limitations on the government’s ability to bring obstruction charges in tax cases under the so-called Omnibus Clause of 26 U.S.C. § 7202(a).  Since that time, tax practitioners have been watching to see how impactful the […] Read More…