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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak on Handling Partnership Examinations

We 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…

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Journal of Tax Practice and Procedure – The News from the FBAR Front Isn’t All Bad, It Only Seems That Way Sometimes by ROBERT HORWITZ

“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…

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JONATHAN KALINSKI Quoted in Tax Notes Article About Cannabis Businesses

The 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…

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Crown Jewels. Operation Hidden Treasure. STEVEN TOSCHER Quoted in Forbes Article

Steven Toscher recently had the opportunity to moderate a Federal Bar Association panel on the IRS new Office of Fraud Enforcement. While much attention was paid on the panel  to the  unveiling some of IRS Crown Jewels  by the new OFE Director Damon Rowe and it’s “Operation Hidden Jewels” in its cryptocurrency enforcement efforts, Steve […] Read More…

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FinCEN Notice 2020-2: FinCEN’s Intent to Add Crypto Currency to the List of FBAR Reportable Accounts – by JONATHAN KALINSKI and GARY MARKARIAN

The price of Bitcoin rose dramatically in 2020 and even doubled in price since the beginning of 2021. On January 1, 2021, Bitcoin was $29,336.31 and on February 21, 2021, it was $58,012.09. Many who have sold their Bitcoin have made a profit. Where there’s profit, there’s income – and where there’s income, there’s tax.  […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and JONATHAN KALINSKI to speak on Handling Cannabis Tax Examinations: Sec. 280E, Audits, IRS Guidance, Reporting Requirements

We are pleased to announce that Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Handling Cannabis Tax Examinations: Sec. 280E, Audits, IRS Guidance, Reporting Requirements” on Wednesday, March 24, 2021, 10:00 a.m. – 11:50 a.m. (PST), 1:00 p.m. – 2:30 p.m. (EST). This CLE/CPE webinar will provide tax […] Read More…

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STEVEN TOSCHER to Speak at Upcoming Orange County Estate Planning Council on When a Tax Case Goes Criminal – How to Avoid It and How to Deal with It – March 23, 2021

We are pleased to announce that Steven Toscher will be speaking at the upcoming Orange County Estate Planning Council webinar, “When a Tax Case Goes Criminal – How to Avoid It and How to Deal with It” on Tuesday, March 23, 2021, 4:45 p.m. – 6:00 p.m. (PST) While criminal tax prosecutions are at a […] Read More…

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STEVEN TOSCHER to Speak at Upcoming Florida Tax Institute on Increased IRS Exam Activity on High Wealth Taxpayers and Their Investment Structures – March 11, 2021

We are pleased to announce that Steven Toscher, along with Fred Murray, Deborah Palacheck and Clifford Scherwinski will be speaking at the upcoming Florida Tax Institute webinar, “Increased IRS Exam Activity on High Wealth Taxpayers and Their Investment Structures” on Thursday, March 11, 2021, 9:25 a.m. – 10:25 a.m. (PST). The IRS has again increased […] Read More…

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STEVEN TOSCHER and JONATHAN KALINSKI to Speak at Upcoming 45th Annual Federal Bar Association Tax Conference – March 5, 2021

We are pleased to announce that Steven Toscher and Jonathan Kalinski will be speaking at the  upcoming Federal Bar Association webinar: Steven Toscher – “Fraud Enforcement Office,”Friday, March 5, 2021, 11:30 a.m. – 12:30 p.m. (PST) Jonathan Kalinski – “Cannabis is Going National – Opportunities and Pifalls,Friday, March 5, 2021, 1:00 p.m. – 2:00 p.m. […] Read More…

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Eighth Circuit Rehears Coffey, but the Result Is the Same by Robert S. Horwitz

On December 16, 2020, the Eighth Circuit issued its opinion in Coffey v. Commissioner, holding that a tax return filed with the U.S. Virgin Islands Bureau of Internal Revenue (“VIBIR”) was not a filing with the IRS and, thus, the three year statute of limitations on assessment was not triggered. See https://www.taxlitigator.com/a-return-by-any-other-name-by-robert-s-horwitz/.  On February 10, […] Read More…

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Where is My “Tax Home” or Residency in a Post-COVID World? By Cory Stigile

In Soboyede v. Comm’r, T.C. Summary Opinion 2021-3, the Tax Court addressed whether the taxpayer’s travel expenses while performing legal work in Washington were incurred “while away from home” such that they could be deducted as ordinary and necessary travel expenses under IRC Section 162.   While this is a non-precedential opinion, it is a helpful […] Read More…

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The Corporate Transparency Act takes on Serious Tax Fraud: Say Goodbye to Not Disclosing Beneficial Owners of Entities by Sandra R. Brown and Michael Greenwade

Historically, most—if not all—states in the U.S. have not required the disclosure of the beneficial owners of corporations, LLCs, or similar entities formed under the laws of the State.[i]  However, with the enactment of the Corporate Transparency Act (CTA)[ii], as part of the 2021 National Defense Authorization Act, the non-disclosure approach has come to an […] Read More…

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