TAXLITIGATOR Blog

New IRS Voluntary Disclosure Application Gets More Virtual by: JONATHAN KALINSKI and PHILIPP BEHRENDT

This week, the IRS updated the Voluntary Disclosure Practice Preclearance Request and Application, Form 14457. Most notably, it includes a new section on disclosing virtual currency information.  When it comes to the new information that has to be disclosed, two points stand out. The first is that you must disclose all aliases and citizenship.  Although […] Read More…

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STEVEN TOSCHER and SANDRA BROWN to Speak at Upcoming Federal Bar Association 46th Annual Tax Conference

Please join us March 3-4, 2022 for the Federal Bar Association 46th Annual Tax Conference.Examine important tax developments and emerging policy issues in nearly 20 educational sessions featuring notable speakers from the Internal Revenue Service, Treasury Department, Department of Justice, White House, and Congress. Steven Toscher – Enforcement & Criminal | Hot Topics: IRS Enterprise Compliance […] Read More…

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EVAN DAVIS Quoted in Law360 Regarding a Cryptocurrency Refund Case

The Internal Revenue Service hasn’t offered specific guidance regarding whether cryptocurrency staking constitutes taxable income upon receipt, leaving those engaged in the activity, which implicates substantial sums of potential government revenue, unsure about their tax obligations. “There are a lot of people that use Tezos,” Evan Davis of Hochman Salkin Toscher Perez PC told Law360. […] Read More…

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JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Taxation of Digital Asset Transactions: Impact of New Infrastructure Bill, Cash Transactions, Reporting, Tax Planning” on Thursday, March 3, 2022, 10:00 a.m. – 11:30 a.m. (PST). On Nov. 15, 2021, President Biden signed the Infrastructure Investment and Jobs Act […] Read More…

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STEVEN TOSCHER Quoted in Forbes Article DOJ Names Experienced Cybercrime Prosecutor As First Crypto Enforcement Director

“The appointment underscores how pervasive cryptocurrency and other forms of digital monetary exchange have become in our financial system and the importance of coordinated and robust enforcement needed to insure the integrity of these important tools of modern commerce,” says Steve Toscher, a tax litigator with Hochman Salkin Toscher Perez P.C.” Click Here for Full Article.

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It Ain’t Over Until It’s Over- The 9th Circuit Clears Up Some Questions Regarding the Statute of Limitations for Criminal Tax Evasion by STEVEN TOSCHER, SANDRA BROWN and PHILIPP BEHRENDT

A famous baseball player once said: “It ain’t over until it‘s over.“[i]  Apparently, as the 9th Circuit recently reminded us, in addressing the question of when the statute of limitation starts anew in a tax evasion case, this quote rings equally true outside of baseball. In the case United States v. Orrock, No. 19-10388 (9th […] Read More…

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ROBERT HORWITZ Recognized for His Outstanding Contributions in the Field of Tax Law from the Orange County Bar Association Tax Section

We are very pleased to announce that our friend and colleague Robert Horwitz has been recognized for his outstanding contributions in the field of taxation by the Orange County Bar Association Tax Section.   Robert has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax […] Read More…

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Hochman Salkin Toscher Perez P.C. Welcomes Associate Philipp Behrendt

Philipp Behrendt is a graduate of University of Southern California (USC) Gould School of Law (LL.M.) and a former associate of the leading German tax firm Flick Gocke Schamburg. Philipp’s prior experience includes representing wealthy individuals and companies in global tax settings, cross-border investigations and audit matters, as well as tax compliance issues arising from […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to Speak at Upcoming Lorman Webinar on Form 8300 Reporting Requirements

We are pleased to announce that Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming Lorman Educational Services Webinar on Form 8300 Reporting Requirements, Wednesday February 23, 2022, 10:00 a.m. – 11:40 a.m. (PST). The law requires that trades and businesses report cash payments of more than $10,000 to the federal government by filing Form […] Read More…

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STEVEN TOSCHER to Speak at Upcoming Florida Tax Institute

We are pleased to announce that Steven Toscher will be speaking at the upcoming Florida Tax Institute on Audits and Tax Controversy, Thursday February 3, 2022, 10:00 a.m. – 11:30 a.m. (EST). The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions.  The reviews are expected to include […] Read More…

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SANDRA BROWN to Speak at Upcoming ABA Virtual 2022 Midyear Tax Meeting

We are pleased to announce that Sandra R. Brown will be presenting at the upcoming American Bar Association Virtual 2022 Midyear Tax Meeting, Tuesday, February 1, 2022, 2:30 p.m. – 3:00 p.m. (ET).  Sandra will provide updates on “Important Criminal Developments” on behalf of the Tax Section’s Civil and Criminal Tax Penalties (CCTP) Sentencing Subcommittee.   […] Read More…

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FinCEN Proposed Regulations Put “Transparency” in the Corporate Transparency Act by Requiring Disclosure of Beneficial Owners of LLCs and Other Entities By EVAN J. DAVIS

The dirty little secret, that isn’t so secret after the release of the Pandora Papers (Pandora Papers – ICIJ), is that the United States is a tax and money-laundering haven for much of the world because, unlike most countries, many U.S. states allow persons to own entities without revealing their ownership to authorities.  Last month, […] Read More…

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