TAXLITIGATOR Blog

Same Procedure as Every Year – the FBAR Deadline Approaches by ROBERT HORWITZ and PHILIPP BEHRENDT

We frequently blog on cryptocurrency tax matters and on cases involving the Foreign Bank Account Report (FBAR) penalty. The question of whether FBARs have to be filed must be answered by taxpayers and tax return preparers every year around the same time. For some years now, with the IRS’s increased focus on virtual currency, holders […] Read More…

Read More

Save the Date – UCLA 38th Annual Tax Controversy Institute – October 27, 2022

Dear Colleague- We cordially invite you to save the date for this years UCLA Extension Tax Controversy Institute which will be live this year and held on October 27, 2022 at the Beverly Hills Hotel in Beverly Hills, California.  The Institute is entering its 38th year and is recognized as one of the top tax controversy […] Read More…

Read More

STEVEN TOSCHER to Speak at Upcoming 14th Annual STEP International Tax and Estate Planning Forum

We are pleased to announce that Steven Toscher will be speaking at the upcoming 14th Annual STEP International Tax and Estate Planning Forum seminar, “Cryptocurrency Developments” on Thursday, May 5, 2022, 3:00 p.m. (PST) at the Surf & Sand Resort, Laguna Beach, California.  Cryptocurrency has become a fact of life for professional advisors which cannot be ignored. Join Steve for a keynote presentation […] Read More…

Read More

JONATHAN KALINSKI to Speak on to Speak Tax Implications of Acquiring, Holding or Selling NFTs

We are pleased to announce that Jonathan Kalinski will be speaking at the upcoming BHBA webinar, “Tax Implications of Acquiring, Holding or Selling NFTs” on Friday, April 1, 2022, 12:30 p.m. – 1:30 p.m. (PST). The recent explosion of the creation and sale of NFTs has brought about significant concerns regarding the taxation of these […] Read More…

Read More

Sixth Circuit Deals Major Blow to IRS for Failing to Follow Administrative Procedures Act Notice & Comment Requirements Before Issuing Listed Transaction Notice by ROBERT S. HORWITZ

As part of the 2004 Jobs Act, Congress added several provisions as part of the interminable effort to clear the tax system of abusive tax shelters: Sec. 6111, which requires “material advisors” to file returns disclosing information about reportable (including listed transactions); Sec. 6700, which imposes a penalty for failure to file a return, or […] Read More…

Read More

LACEY STRACHAN and MICHAEL GREENWADE Publish Article in Los Angeles Lawyer Magazine

We are pleased to announce that Lacey Strachan and Michael Greenwade have published an article, “Close It Out — Past, Present & Future,” in the February issue of Los Angeles Lawyer Magazine. In 2021, the Tax Court ruled against the IRS in Crandall v. Commissioner, holding the IRS to the finality of a closing agreement.  […] Read More…

Read More

SANDRA BROWN to Speak at Upcoming 37th Annual National Institute on White Collar Crime

We are pleased to announce that Sandra Brown will be speaking at the upcoming ABA seminar, “In the Eye of the Beholder: What Moves a Tax Case from Civil to Criminal” on Wednesday, March 2, 2022, 10:00 a.m. – 11:45 a.m. (PST). The IRS puts the current gross tax gap at more than $1 trillion dollars. The gap consists of underreporting, […] Read More…

Read More

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…

Read More

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…

Read More

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…

Read More

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…

Read More

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.

Read More

Important This site makes use of cookies which may contain tracking information about visitors. By continuing to browse this site you agree to our use of cookies.