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UCLA 35th Annual Tax Controversy Institute – Message from Institute Chair STEVEN TOSCHER – Save the Date – October 20, 2020

It doesn’t seem like very long ago that we were all together last October at the 2019 UCLA Extension Tax Controversy Institute. Much has changed since then and I hope all of you are coping in these challenging times. We are saving the date of October 20, 2020 for this year’s Institute.  We all hope we […] Read More…

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IRS Issues Temporary Procedures to Fax Form 1139 and 1045 Tentative Refund Claims for Net Operating Losses By Robert Horwitz and Tenzing Tunden

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act)[i] enacted many relief provisions for taxpayers.. In particular, the CARES act will allow taxpayers who have net operating losses (NOLs) for tax year 2018, 2019, and 2020 to carry the NOL back to each of the five preceding years unless the taxpayer elects to waive […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to speak on Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easement Transactions

We are pleased to announce that three of our principals  Steven Toscher and Michel Stein will be speaking at the upcoming Strafford webinar on Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easement Transactions, Tuesday, May 5, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. The IRS recently announced a significant increase in enforcement actions for syndicated […] Read More…

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Tax Court Finds a Personal Injury Attorney Was Not a Real Estate Professional By: LACEY STRACHAN

On April 13, 2020, the Tax Court issued an opinion in Hakkak v. Comm’r, T.C. Memo 2020-46, holding that a taxpayer was not a real estate professional in the tax years at issue for purposes of being able to qualify for the exception to the rule that rental activities are per se passive under the […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to speak on Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471

We are pleased to announce that three of our principals Steven Toscher and Michel Stein will be speaking at the upcoming Strafford webinar on Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471, Thursday April 30, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. Cross-border tax audits are expanding dramatically, and the resulting tax assessments […] Read More…

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IRS Opens the Flood Gates for Relief for Filing, Payment Deadlines (Including Tax Court Petitions and Refund Suits) by ROBERT S. HORWITZ

IRC Section 7508A gives the Treasury Secretary the power to postpone certain deadlines in the case of a Presidentially-declared disaster.  Previously, the Secretary had postponed until July 15, 2020, the time for filing income tax returns and paying federal income tax due April 15, 2020.  On April 9, the IRS issued Notice 2020-23, which postpones […] Read More…

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Taxpayer First Act and Third Party Notices – New Rules and New Interpretations to the Notice Requirements By SANDRA R. BROWN and TENZING TUNDEN

The Internal Revenue Service (“IRS”) has several tools to utilize in obtaining information about a taxpayer’s financial records.  One of these tools involves contacting third parties.  Those third parties may be a taxpayer’s business associates or even friends and relatives.  Third parties may, however, also be governmental agencies.  While there are rules in place as […] Read More…

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No Mulligan for Tax Offender, Penalties and Interest Count for Criminal Tax Loss, but Restitution Doesn’t Include Tax Says Second Circuit by EVAN J. DAVIS

Do-overs are rare in criminal law, unlike a weekend golf game.  Finality is an important factor in what appellate courts do, which is why they establish hard-to-meet standards for reversal such as “plain error.”  Another tip: judges don’t like defendants to use the time between pleading guilty and being sentenced to commit the same crimes […] Read More…

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State Tax Agencies Preparing for Increased Transfer Pricing Enforcement by STEVEN TOSCHER, LACEY STRACHAN and TENZING TUNDEN

Transfer pricing tax disputes are the highest dollar for dollar cases that are before the U.S Tax Court currently, with cases that involve cross-border transactions of large multinational corporations. These are particularly important tax matters for states where multinational corporations are headquartered and/or conduct business.  But transfer pricing controversies are not limited to large multinationals—the […] Read More…

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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to speak on Partnership Audit Adjustments Under the Centralized Audit Regime

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at an upcoming Strafford webinar, “Partnership Audit Adjustments Under the Centralized Audit Regime” for Wednesday, April 22, 2020, 1:00 p.m. – 2:50 p.m. EDT/ 10:00 a.m. – 11:50 a.m. PST This webinar will cover practical considerations for partners and […] Read More…

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ROBERT HORWITZ and CORY STIGILE to speak on COVID-19 Administrative and Legislative Relief

We are pleased to announce that two of our principals Robert Horwitz and Cory Stigile  will be speaking at the upcoming Beverly Hills Bar Association webinar on COVID-19 Administrative and Legislative Relief, Wednesday, April 8, 2020, 3:30 p.m.-4:30 p.m. This is a free webinar being presented by the Beverly Hill Bar Association as a public […] Read More…

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FTB, OTA Extend Filing Deadlines for Protests, Appeals, Briefing — Will Treasury Follow Suit by ROBERT S. HORWITZ

On March 30, 2020, the California Franchise Tax Board (FTB) issued Notice 2020-02.  Based on Governor Newson’s March 12, 2020, executive order authorizing the FTB to use its administrative powers to grant extensions, the notice extends the deadline for filing claims for refund, protests of Notices of Proposed Assessment (NPA), appeals and petitions for rehearing […] Read More…

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