TAXLITIGATOR Blog

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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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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