TAXLITIGATOR Blog
Referrals of Puerto Rico Cases to the IRS: The GAO’s Puerto Rico Report and the IRS’s Campaign 685 Enforcement Trajectory for Act 60 and Crypto by Steven Toscher, Evan Davis, and Philipp Behrendt
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Friday, December 19, 2025
Did you or your client move to Puerto Rico, or are you considering a move? Many Americans have taken advantage of the very favorable tax treatment available to Puerto Rican residents, but not all of them have complied with the strict requirements for favorable tax treatment. But, related to the number of Americans who claim […] Read More…
Read MoreWhat Can We Expect from the IRS Criminal Investigation—the CI Annual Report for 2025 by Steven Toscher, Sandra R. Brown and Philipp Behrendt
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 17, 2025
The IRS Criminal Investigation’s FY 2025 Annual Report was just issued and it tells practitioners where CI spent time, what CI measured, and where CI believes it produced results. Unfortunately, it does not tell us where CI is going –but it does give us some clues and reflects a vibrant CI with significant accomplishments for […] Read More…
Read MoreThe Government Learns a Costly ($24 Million) Lesson in Pleading by Robert Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 10, 2025
Rule 12(b) of the Federal Rules of Civil Procedure allows a defendant to raise certain defenses in its responsive pleading or by motion, including under 12(b)(6), failure to state a claim upon which relief can be granted. A 12(b)(6) motion was a favorite motion of attorneys of the late Tax Division to get rid of […] Read More…
Read MoreMichel R. Stein to Speak at Upcoming Barbri Webinar on IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, December 09, 2025
We are pleased to announce that Michel R. Stein along with Thomas Giordano-Liscari (Greenberg Glusker) will be speaking at the upcoming Barbri webinar on IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process, Wednesday, December 10, 2025, 10:00 a.m. – 11:30 a.m. (PST). This webinar will provide tax professionals […] Read More…
Read MoreSandra R. Brown to Speak at Upcoming PLI Institute Webinar – Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 08, 2025
We are pleased to announce that Sandra R. Brown will be speaking at the upcoming PLI Institute seminar on Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know at Sofitel Los Angeles, December 10, 2025, 4:45 p.m. – 5:45 p.m. Sandra will be joined by Bradley M. Seltzer and Andrew Weiner […] Read More…
Read MorePlease Join US – ABA Tax Section 2025 Criminal Tax Fraud and Tax Controversy – December 11-13, 2025
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, December 05, 2025
We are all looking forward to the ABA Tax Section 2025 Criminal Tax Fraud and Tax Controversy Conference next week, December 11-13, 2015, in Las Vegas, where there will be record attendance and an excellent line up of cutting-edge programs. Conference Co-Chair Steven Toscher will be introducing former IRS Commissioners Charles Rettig and Danny Werfel […] Read More…
Read MoreDennis Perez, Robert S. Horwitz and Sebastian Voth to Speak at Upcoming CalCPA Webinar – Handling a Case Before California Office of Tax Appeals
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, December 04, 2025
We are pleased to announce that Dennis Perez, Robert S. Horwitz and Sebastian Voth will be speaking at the upcoming CalCPA Tax Talk webinar on Office of Tax Administration: Handling a Case Before California Office of Tax Appeals, Tuesday, December 9, 2025, 9:00 a.m. – 10:30 a.m. (PST). This webinar will guide tax professionals and advisers on the stages […] Read More…
Read MoreUSC Gould School of Law 2026 Tax Institute – January 26-28, 2026
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, December 01, 2025
We are pleased to announce that four of our attorneys will be speaking at the upcoming USC Gould School of Law 2026 Tax Institute, January 26-28, 2026 at the Sheraton Grand, Los Angeles on the following key topics: Sandra R. Brown A Conversation with the IRS Criminal Investigation Special Agent-In-Charge for the Los Angeles Field […] Read More…
Read MoreMichel R. Stein to Speak at UT Law 73rd Annual Taxation Conference – The Latest Tax Court Jurisdictional Disputes and Other Rolling Topics
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, November 25, 2025
We are pleased to announce that Michel R. Stein will be speaking at the upcoming UT Law 73rd Annual Taxation Conference on You Can’t Always Get What You Want . . . But You Can Try Sometimes: The Latest Tax Court Jurisdictional Disputes and Other Rolling Topics being held at the AT&T Conference Center, Austin, […] Read More…
Read MoreTAXES Magazine – The Shifting Ground of Subchapter K: Economic Substance in Focus – by Sebastian Voth
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, November 21, 2025
We are pleased to announce that Sebastian Voth’s article, The Shifting Ground of Subchapter K: Economic Substance in Focus, was published in the November 2025 issue of TAXES Magazine. Although the IRS issued guidance this year announcing its intent to withdraw certain basis-shifting regulations and granting penalty relief for failure to disclose related transactions, a key […] Read More…
Read MoreHochman Salkin Toscher Perez P.C. Recognized by Best Law Firms
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, November 20, 2025
Hochman Salkin Toscher Perez, P.C is very honored that once again the firm along with five (5) of our Principals have been ranked as National and Regional Tiers 1 in Tax Litigation and Controversy by Best Law Firms. Founded in 1960, Hochman Salkin Toscher Perez P.C., is internationally recognized as the preeminent tax law firm on the West Coast. The reputation […] Read More…
Read MoreMelissa Briggs to Speak at Upcoming California Lawyers Association Webinar – Women in Tax – Hot Topics in Federal Tax Litigation
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, November 18, 2025
We are pleased to announce that Melissa Briggs will be speaking at the upcoming California Lawyers Association Women in Tax Hot Topics in Federal Litigation webinar, Thursday, November 20, 2025, 12:00 p.m. – 1:00 p.m. (PST). This program will provide the learner with updates regarding cases pending or decided in the Supreme Court, United States Courts of […] Read More…
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