TAXLITIGATOR Blog

MICHEL STEIN, EDWARD ROBBINS, JR. and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process” on Wednesday, October 4, 2023 from 10:00 a.m. – 11:30 a.m. (PST). The IRS employs strict standards for determining whether a taxpayer qualifies for penalty […] Read More…

Read More

STEVEN TOSCHER, SANDRA BROWN and JONATHAN KALINSKI to Speak at Upcoming CalCPA Webinar

STEVEN TOSCHER, SANDRA BROWN and JONATHAN KALINSKI to Speak at Upcoming CalCPA Webinar

We are pleased to announce that Steven Toscher, Sandra Brown, and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar “Handling Cannabis Tax Examination 2023” Tuesday, September 26, 2023, 9:00 a.m. – 10:00 a.m. (PST). The sale and distribution of cannabis for recreational or medical use is a powerful economic engine generating billions in annual revenue, with over […] Read More…

Read More

Los Angeles Lawyer – Walking the Tightrope of Employment Tax Law by JONATHAN KALINSKI and DENNIS PEREZ

Los Angeles Lawyer – Walking the Tightrope of Employment Tax Law by JONATHAN KALINSKI and DENNIS PEREZ

We are pleased to announce that an article entitled “Walking the Tightrope of Employment Tax Law,” by Jonathan Kalinski and Dennis Perez, is featured as the Los Angeles Lawyer Magazine’s September 2023 Cover Story. The article discusses both federal and California worker classification issues and the different standards for each. Now that California has adopted the ABC […] Read More…

Read More

Strafford – Federal and State Tax Residency Rules: Latest IRS Examination Guidance and Navigating State Tax Regulations – September 21, 2023

Strafford – Federal and State Tax Residency Rules: Latest IRS Examination Guidance and Navigating State Tax Regulations – September 21, 2023

We are pleased to announce that Steven Toscher, Michel Stein, and Robert Horwitz will be speaking at the upcoming Strafford webinar “Federal and State Tax Residency Rules: Latest IRS Examination Guidance and Navigating State Tax Regulations” Thursday, September 21, 2023, 10:00 a.m. – 11:50 a.m. (PST). This course will guide tax professionals and advisers on the […] Read More…

Read More

Crypto Enthusiasts and Puerto Rico’s Tax Exemption: A Friendship under IRS Scrutiny by: EVAN DAVIS and PHILIPP BEHRENDT

Crypto Enthusiasts and Puerto Rico’s Tax Exemption: A Friendship under IRS Scrutiny by: EVAN DAVIS and PHILIPP BEHRENDT

Nestled in the heart of the Caribbean, Puerto Rico beckons with its breathtaking natural beauty, vibrant culture, and alluring lifestyle, making it a tempting living space for those seeking a tropical paradise while enjoying the benefits of living in a U.S. territory. However, those who move to Puerto Rico in whole or in part for […] Read More…

Read More

IRS Proposes New Regulations on Broker Reporting Digital Asset Transactions with Hidden Additional Guidance beyond Broker Reporting Part 1 by: PHILIPP BEHRENDT

IRS Proposes New Regulations on Broker Reporting Digital Asset Transactions with Hidden Additional Guidance beyond Broker Reporting Part 1 by: PHILIPP BEHRENDT

The year 2023 is witnessing transformative changes in the tax landscape for digital assets, with the Internal Revenue Service (IRS) poised to usher in a significant transformation. The official version of the proposed regulations for broker reporting under Code Secs. 6045 and 6045A is scheduled for August 29, 2023. However, ahead of this official release, […] Read More…

Read More

UCLA Tax Controversy Institute is Now Open for Registration

UCLA Tax Controversy Institute is Now Open for Registration

Dear Colleague- We are pleased to announce that registration is now open for this years UCLA Extension Tax Controversy Institute which will be live this year and held on October 26, 2023 at the Beverly Hills Hotel in Beverly Hills, California.  The Institute is entering its 39th year and is recognized as one of the premier tax […] Read More…

Read More

MICHEL STEIN, EDWARD ROBBINS, JR. and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

MICHEL STEIN, EDWARD ROBBINS, JR. and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process” on Wednesday, September 6, 2023 from 10:00 a.m. – 11:30 a.m. (PST). The IRS employs strict standards for determining whether a taxpayer qualifies for penalty […] Read More…

Read More

SANDRA BROWN to Speak at Upcoming 40th International Symposium on Economic Crime

SANDRA BROWN to Speak at Upcoming 40th International Symposium on Economic Crime

We are pleased to announce that Sandra R. Brown will be speaking on upcoming seminars at the 40th Symposium on Economic Crime – Jesus College, University of Cambridge, being held at Jesus College, a College within the University of Cambridge, September 3–10, 2023. Sandra will be participating on the following panels Recent United States initiatives to enforce integrity Tuesday, September 4, 2023, 4:15 […] Read More…

Read More

The Tax Adviser – Considerations for IRS examinations of ERC claims by Cory Stigile

The Tax Adviser – Considerations for IRS examinations of ERC claims by Cory Stigile

This column summarizes recent developments in the IRS’s civil enforcement of the employee retention credit (ERC), with a focus on its examinations. The IRS has been active in alerting taxpayers and tax professionals regarding attempts to promote ERCs to ineligible taxpayers, recently including ERC schemes on its 2023 Dirty Dozen list (News Release IR-2023-71). Click […] Read More…

Read More

New Audit Targets: IRS Focuses on Employee Stock Ownership Plans (ESOPs) by: SANDRA BROWN and PHILIPP BEHRENDT

New Audit Targets: IRS Focuses on Employee Stock Ownership Plans (ESOPs) by: SANDRA BROWN and PHILIPP BEHRENDT

In a recent announcement, titled: “IRS cautions plan sponsors to be alert to compliance issues associated with ESOPs” (IR-2023-114, dated August 9, 2023), the Internal Revenue Service (IRS) highlighted its expanded efforts to ensure high-income taxpayers pay their fair share of taxes. The focus of this announcement is on compliance issues associated with Employee Stock […] Read More…

Read More

Farhy Reminds the IRS to Turn Square Corners, Not Cut Corners by PHILIPP BEHRENDT

Farhy Reminds the IRS to Turn Square Corners, Not Cut Corners by PHILIPP BEHRENDT

Introduction: The recent case of Farhy v. Commissioner has brought attention to an essential aspect of the tax collection process – the assessment authority for penalties by the Internal Revenue Service (IRS). Ed Robbins, who argued this case on behalf of the taxpayer, explains the impact of this taxpayer’s victory in the latest volume of […] Read More…

Read More