Our Blog

STEVEN TOSCHER and MICHEL STEIN to Speak on Taxpayer Residency at an Upcoming Strafford Webinar

Steven Toscher and Michel Stein will be speaking at an upcoming presentation of the Strafford webinar Taxpayer Residency: New IRS Examination Guidance, Navigating Federal and State Tax Residency Rules scheduled for Tuesday, December 18th, 10:00 a.m. to 11:50 a.m. PST/1:00 p.m. to 2:50 p.m. EST. This webinar will guide tax professionals and advisers on recent […] Read More…

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Tax Notes – When Noncompliance With FATCA Is More Than a Civil Tax Matter by SANDRA BROWN

In this article, Sandra Brown examines the government’s use of 18 U.S.C. section 371 to charge related criminal violations under the Foreign Account Tax Compliance Act. Following on the heels of the Justice Department’s expanded use of the federal statutory reporting obligations that require some U.S. persons to disclose their offshore bank accounts by filing […] Read More…

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MICHEL STEIN Will Participate In The Panel Titled “Cryptocurrency: What Every Practitioner Needs to Know” at the 2018 New England IRS Representation Conference

We are pleased to announce that Michel Stein will be participating at an upcoming panel at the 2018 New England IRS Representation Conference on Friday, November 30th from 1:45 p.m. to 2:45 p.m. The presentation will provide tax professionals with a critical first look at new IRS initiatives on taxpayer compliance and reporting obligations for […] Read More…

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EDWARD ROBBINS, JR., to Speak on Ethical Challenges in Tax Practice at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Edward Robbins, Jr. will be speaking on Wisdom Across the Generations: How to Address Ethical Challenges in Tax Practice at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 13, 2018 from 2:15 […] Read More…

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DENNIS PEREZ to Speak at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Dennis Perez will speak on Ethical and Other Issues When Representing Non-Compliant Taxpayers: Domestic and Foreign Voluntary Disclosures In a Post-Program World at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Friday, December 14, […] Read More…

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ROBERT HORWITZ to Speak at The Knowledge Group Overcoming FBAR Penalties: Best Practices and Practical Tips Webinar

We are pleased to announce that Robert Horwitz will be speaking at an upcoming webinar on Overcoming FBAR Penalties: Best Practices and Practical Tips, January 17, 2019, 9:00 a.m. to 11:00 a.m. (PST)/12:00 p.m. – 2:00 p.m. (ET). Over the years, the Internal Revenue Service (IRS) has enforced drastic penalties for inaccurate, late, and non-filing […] Read More…

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SANDRA BROWN, Speaker on Criminal Trial Practice at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Sandra Brown will be speaking on Criminal Trial Practice/Ask the Experts at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 14, 2018 from 1:30 p.m. to 3:00 p.m. The most difficult topics […] Read More…

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SANDRA BROWN, Co-Moderator at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Sandra Brown will be Co-Moderator of the Criminal Tax Workshop at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 13, 2018 from 9:30 a.m. to 12:00 p.m. Taxpayers can become aware they […] Read More…

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UCLA Extension The Vets Count Scholarship – Double Your Impact This Veterans Day

UCLA Extension is proud to support our veterans as they look to gain new skills and aim to advance their careers through the new Vets Count Scholarship Fund. Vets Count is for active and retired military personnel who are working to realize their career goals in tax, accounting, wealth management, and other areas of the […] Read More…

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California’s Office of Tax Appeals Approves Drop and Swap Transaction In Important Decision for California Real Estate Investors by Robert S. Horwitz

When a partnership wants to sell real property it sometimes has a problem: some of the partners want to cash out while others want to do a like-kind exchange and remain invested in real property.  The “drop and swap” transaction was designed to address this problem.  Prior to the sale, the partnership distributes, in exchange […] Read More…

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DENNIS PEREZ Quoted in Tax Notes Article: IRS Using FATCA Criminal Indictments to Pursue Tax Evaders

Ten years after starting to aggressively pursue Swiss banks that helped U.S. persons evade taxes, the IRS is continuing to mine the trove of information gathered to criminally pursue the account holders and their facilitators. A pair of practitioners with extensive experience at the IRS said U.S. taxpayers with undisclosed foreign accounts who do not […] Read More…

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Maintaining Privileges When Kovel Accountants Prepare Tax Returns by Evan Davis

Maintaining Privileges When Kovel Accountants Prepare Tax Returns by Evan Davis

Is this merely a theoretical problem? No. The IRS and Justice Department are pursuing Kovel communications aggressively. Lawyers who aren’t careful about how and when they use Kovel accountants are at serious risk of losing privilege protections and giving the government a window into the attorney-client relationship. Although it’s impossible to entirely avoid risk in this area, here are suggestions […] Read More…

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