TAXLITIGATOR Blog

STEVEN TOSCHER, DENNIS PEREZ, MICHEL STEIN and SANDRA BROWN to Speak at Upcoming USC Gould School of Law 2022 Tax Institute

Please join us January 24-26, 2022 for the USC Gould School of Law 2022Tax Institute virtual event. Meet with fellow tax professionals and address the cutting-edge tax issues affecting the industry. This three-day institute includes discussions, networking opportunities, breakout sessions and workshops led by heavy hitters in the field. We have an excellent line up of programs – […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to Speak on Tax Reporting of Cryptocurrency

We are pleased to announce that Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming Strafford Webinar on Tax Reporting of Cryptocurrency: Calculating Basis, Income, and Gain, Thursday, January 20, 2022, 10:00 a.m. – 11:50 a.m. (PST). This course will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and […] Read More…

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Just When You Thought It Was Safe to Go into the Water, Along Comes the Fifth Circuit by ROBERT S. HORWITZ

I previously blogged on the Ninth Circuit’s decision in United States v. Boyle, 991 F.3d 1077 (2021), where the Court held the $10,000 non-willful FBAR penalty applies on a per-form rather than per-account basis.  Several district courts had reached the same conclusion, including the district court in United States v. Bittner, 469 F.Supp.3d 709 (ED […] Read More…

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MICHEL STEIN Quoted in Tax Notes Article Cryptocurrency Soft Letters Yield Big Bang for the Buck

The IRS is getting more information from its cryptocurrency exchange John Doe summonses, which it will use to fuel another round of soft letters to account holders, according to an agency official. Michel R. Stein of Hochman Salkin Toscher Perez PC noted that the Coinbase summons used older tax years but the same dollar threshold […] Read More…

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SANDRA BROWN to Speak at Upcoming Practising Law Institute Seminar at the Beverly Hills Marriott

We are pleased to announce that Sandra Brown along with Sharyn Fisk, IRS Office of Professional Responsibility, Caroline D. Ciraolo, and Bradley M. Seltzer will be speaking at the upcoming PLI Institute Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021 LA webinar, on “Balancing Tax Planning, Advocacy and Professional Ethics: The Rules That Every Tax Advisor […] Read More…

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STEVEN TOSCHER TO Speak at Upcoming University of Texas 69th Annual Taxation Conference

We are pleased to announce that Steven Toscher along with Larry Campagna, Honorable Elizabeth Copland and Charles Muller III will be speaking at the upcoming University of Texas 69th Annual Taxation Conference webinar, on “What Does Enforcement Look Like Today?” on Thursday December 2, 2021, 1:30 p.m. – 3:00 p.m.(CST). While Congress debates whether to fund more IRS enforcement, the […] Read More…

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SANDRA BROWN to Speak at Upcoming Freeman Law International Tax Symposium

We are pleased to announce that Sandra Brown will be speaking at the upcoming Freeman Law International Tax Symposium webinar, on “International Criminal Tax” on Friday, November 19, 2021, 9:25 a.m. – 10:15 a.m. (CST). The United States and other countries have increased focus on investigating and prosecuting international tax crimes.  With the rise of […] Read More…

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EVAN DAVIS Quoted in The Information on Coinbase Earnings Preview; Infrastructure Bill’s Crypto Reporting Rules

Coinbase will report its third-quarter earnings on Tuesday, likely giving more insight into its new offerings, such as its recently announced non-fungible token marketplace. The company, which is the largest crypto exchange in the U.S. by trading volume, could also announce new ventures as it expands further into financial services. It likely won’t be a big […] Read More…

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DENNIS PEREZ to Speak on The California Exodus: How to Exit the State with Your Fortune Intact (or Not)

We are pleased to announce that Dennis Perez will be speaking at the upcoming Professional Advisory Network of the Motion Picture and Television Fund webinar, on “The California Exodus: How to Exit the State with Your Fortune Intact (or Not)” on Thursday November 11, 2021, 12:20 p.m. – 1:28 p.m. (PST). Spurred by increasing taxes, crippling regulations and high-profile tech […] Read More…

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EDWARD ROBBINS, SANDRA BROWN, MICHEL STEIN, EVAN DAVIS, LACEY STRACHAN, and JONATHAN KALINSKI to Speak at the ABA National Institute on Criminal Tax Fraud

We are pleased to let you know that this year’s National Institute on Criminal Tax Fraud and Tax Controversy will be taking place in person in Las Vegas Nevada on December 8 through December 10, 2021. Yes — we are back live and look forward to seeing all of our colleagues up close and personal. The ABA’s COVID-19 protocols will be […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to Speak on IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals, and Litigation

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming Strafford webinar, on “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals, and Litigation” on Thursday November 4, 2021, 10:00 a.m. – 11:50 a.m. (PST).The IRS Large Business and International Division is auditing high net worth individuals and their related […] Read More…

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SANDRA BROWN and JONATHAN KALINSKI to Speak at Upcoming 2021 Annual Meeting on California Tax Bar and California Tax Policy

We are pleased to announce that Sandra Brown will be speaking on “What’s New in Criminal Tax and Fraud Enforcement,” Thursday November 4, 2021, 3:45 p.m. – 5:00 p.m. (PST) and Jonathan Kalinski on Income Tax Hot Topics,” Friday, November 5, 2021, 3:30 p.m. – 5:00 p.m. (PST) at the upcoming 2021 Annual Meeting of […] Read More…

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