TAXLITIGATOR Blog
Michel R. Stein, Robert S. Horwitz and Melissa Briggs to Speak at Upcoming Strafford Webinar – International Tax Disputes, FBAR Violations, Form 3520, Excessive Fines
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Thursday, June 19, 2025
We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Melissa Briggs will be speaking at the upcoming Strafford webinar, International Tax Disputes, FBAR Violations, Form 3520, Excessive Fines, Friday, June 20, 2025, 10:00 a.m. – 11:50 a.m. (PST). This webinar will analyze the most recent and relevant court cases affecting international taxpayers. […] Read More…
Read MoreRobert S. Horwitz to Speak at Upcoming Beverly Hills Bar Association Webinar – BBA Audits: What Tax Attorneys Need to Know
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 29, 2025
We are pleased to announce that Robert S. Horwitz along with Jenni Black (Citrin Cooperman) will be speaking at the upcoming Beverly Hills Bar Association webinar, BBA Audits: What Tax Attorneys Need to Know webinar, Tuesday, June 3, 2025, 12:30 p.m. – 1:30 p.m. (PST). The webinar will provide an in-depth look at how the Bipartisan Budget Act (BBA) has […] Read More…
Read MoreTen Hochman Attorneys Named to the Lawdragon 500 Leading Global Tax Lawyers
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 27, 2025
We are honored and pleased to announce that ten (10) of our Principals have earned a distinguished place in the Lawdragon 500 Leading Global Tax Lawyers. Our firm has one of the deepest and most experienced benches in the civil and criminal tax controversy field and we are proud of such recognition. Lawyers are selected for […] Read More…
Read MoreMichel R. Stein, Robert S. Horwitz and Sebastian Voth to Speak at Upcoming Strafford Webinar – Federal and State Residency Issues
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 21, 2025
We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Sebastian Voth will be speaking at the upcoming Strafford webinar, Federal and State Residency Issues webinar, Thursday, May 22, 2025, 10:00 a.m. – 11:30 a.m. (PST). This webinar will guide tax professionals and advisers on the latest IRS examination guidance on U.S. residency […] Read More…
Read MoreCalifornia Lawyers Association – 2025 DC Delegation
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 20, 2025
Link to DC Delegation Paper For more information, please contact Sebastian Voth at voth@taxlitigator.com. For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com
Read MoreSandra R. Brown and Evan J. Davis to Speak at Upcoming Los Angeles County Bar Association Webinar – Dealing with IRS Criminal Investigation
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 14, 2025
We are pleased to announce that Sandra R. Brown and Evan J. Davis along with Terence Cuff (Loeb & Loeb) will be speaking at the upcoming Los Angeles County Bar Association Dealing with IRS Criminal Investigations webinar, Wednesday, May 21, 2025, 12:00 p.m. – 1:00 p.m. (PST). The panel will discuss challenges and strategies when dealing […] Read More…
Read MoreSteven Toscher and Philipp Behrendt to Speak at Upcoming ABA May Meeting
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 05, 2025
We are pleased to announce that Steven Toscher and Philipp Behrendt will be speaking at the upcoming ABA May Meeting being held at the Marriott Marquis, Washington D.C., May 8-10, 2025. The May Tax Meeting is the Section’s largest and the premier event for lawyers interested in all aspects of tax law. Join us in Washington, […] Read More…
Read MoreCalifornia Lawyers Association – 2025 DC Delegation
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 30, 2025
We are pleased to announce that Sebastian Voth and Philipp Behrendt of our firm are participating in the California Lawyers Association – Taxation Section DC Delegation on May 5-7, 2025. For over 30 years, the Taxation Section has annually selected a delegation to present the ideas and proposals of California tax lawyers to officials in […] Read More…
Read MoreMelissa Briggs to Speak at Upcoming Beverly Hills Bar Association Webinar – Refund Litigation – Where District Court Differs from Tax Court
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 29, 2025
We are pleased to announce that Melissa Briggs along with Gary Slavett (Holtz, Slavett & Drabkin, APLC) will be speaking at the upcoming Beverly Hills Bar Association Refund Litigation – Where District Court Differs from Tax Court webinar, Tuesday, May 6, 2025, 12:00 p.m. – 1:30 p.m. (PST). This program focuses on key procedural and strategic differences […] Read More…
Read MoreNavigating the Pitfalls of California Residency Tax: An Analysis of OTA’s Four Precedential Opinions by Sebastian Voth
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 22, 2025
This article primarily delves into the nuances and lessons learned from the four precedential opinions issued by California’s Office of Tax Appeals (OTA) with respect to the taxation of residents. It also serves as a reminder of the complexity of California’s residency issues and the value of consulting a qualified tax attorney in matters that […] Read More…
Read MoreThe Impact on Criminal Tax Cases Following the Supreme Court’s Holding that Criminal Statute Mens Rea Requirement Means What It Says by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 15, 2025
On March 21, 2025, the Supreme Court handed down a unanimous decision in Thompson v. United States, 604 U.S. ___, a case interpreting 18 USC §1014, making false statements for purposes of influencing certain financial institutions. The defendant in the case is Patrick Thompson. The Court’s opinion does not talk about who Thompson is. He […] Read More…
Read MoreWillful FBAR Penalties: Appellate Update April 2025 by Melissa Briggs
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 09, 2025
Attorneys from our firm have written extensively about foreign bank account reporting (FBAR) penalties.[1] Fifteen years ago, Steven Toscher and Barbara Lubin raised the specter that willful FBAR penalties could violate the Eighth Amendment’s Excessive Fines Clause in the article When Penalties Are Excessive—The Excessive Fines Clause as a Limitation on the Imposition of the Willful […] Read More…
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