TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, October 17, 2019

We are pleased to announce that Michel Stein, will be speaking on “Ethics : When Are You Crossing A Line? Real-Life Ethical Issues in Everyday Tax Practice” at this year’s NYU 78th Institute on Federal Taxation, Thursday, November 14th at the Fairmont Hotel, San Francisco. Click Here for more information. How sure do you have to be before […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, October 16, 2019

Recent changes in federal tax law, along with announcements from the Internal Revenue Service (IRS), have provided more than subtle signals that the federal taxing authorities are looking to increase their focus on big business, sometimes referred to as ‘Corporate America’. Signs can be gleaned from provisions included in the recently passed Taxpayer First Act […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, October 15, 2019

For THIRTY-FIVE YEARS the Annual Tax Controversy Institute has been among the preeminent tax conferences in the United States exclusively dedicated to tax controversy and tax litigation.  This year, I am again honored and privileged to serve as Chair of The Annual Tax Controversy Institute. Institute Chair Emeritus. The Institute was founded by Eugene “Gene” […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, October 09, 2019

The IRS has published long-awaited guidance on the tax treatment of virtual currency transactions, five years after the agency issued its first official pronouncement on cryptocurrency taxation.   To read more Click Here.  

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, October 02, 2019

Plan on joining us on October 22, 2019 to help celebrate the 35th anniversary for one of the preeminent conferences exclusively dedicated to tax controversy and tax litigation.  The Annual Tax Controversy Institute provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience.  For […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, October 01, 2019

The Treasury Inspector General of Tax Administration (TIGTA) issued a report on September 5, 2019, which questioned the IRS Large Business and International Division’s (LB&I) strategy for examining corporate merger and acquisition (M&A) transactions. In the report, the TIGTA stated that the IRS’s approach to M&A transactions has been limited, separate, and distinct from one […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, October 01, 2019

From challenging 30-year precedent that requires small-business owners to turn over self-incriminating tax records to determining the ownership of tax refunds among affiliated groups, the U.S. Supreme Court’s fall docket contains many interesting cases involving federal tax law. As the law stands, under Braswell the “collective entity doctrine” says corporations are treated differently from individuals […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, September 29, 2019

We are pleased to announce that Jonathan Kalinski, along with David Pierce, Pierce Law Group, Greg Zbylut, Singer, Burke Zimmer, Lora Silverman, Ross & Silverman and Schuyler Moore, Greenberg Glusker, will be speaking on “AB 5 Aftermath: Tax, Employment, and Entertainment Fallout,” at Lawry’s The Prime Rib, Beverly Hills on Wednesday, October 2, 2019  at […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, September 29, 2019

For the most part, the deck is stacked in the IRS’s favor when it comes to enforcing administrative summonses.  It’s relatively easy for the government to show that it is entitled to enforcement of a summons through submitting a declaration from an IRS employee that states (often with no supporting facts): The investigation is being […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, September 29, 2019

If you or your client are under examination by the IRS Small Business/Self-Employed (“SB/SE”) division, changes are your case will not be referred criminally.  Currently, criminal fraud referrals from the IRS civil divisions are only approximately 7% of IRS Criminal Investigations Division’s (“CI”) inventory.  Things, however, are changing, and taxpayers and their representatives should take […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 23, 2019

California is showing it is serious about taxing the underground economy. On September 13, Assembly Bill 1296 also known as “AB 1296”, was passed with unanimous consent by the California State Senate and California State Assembly.[1] If signed into law, AB 1296 will authorize California tax agencies to exchange intelligence, data, documents, information, complaints, or lead […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, September 19, 2019

A recent report  by  the Treasury Inspector General for Tax Administration (TIGTA)  after an audit into the Internal Revenue Service’s (IRS) denial of Freedom of Information Act (FOIA) requests for the 2018 fiscal year reminds us of the importance of using FOIA in the course of our dealings with the IRS and to not routinely […] Read More…