Our Blog

STEVEN TOSCHER, MICHEL STEIN and JONATHAN KALINSKI to speak on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques (Discounted Price)

We are pleased to announce that Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the Spidell Webinar–Taxation of Cannabis— on Thursday July 9th  at 10:00 a.m. – 12:00 p.m.  The cannabis business has been growing at very fast pace in California and other jurisdictions since legislative changes legalizing and regulating the sale, […] Read More…

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High Wealth Enforcement is Coming-Get Ready By: STEVEN TOSCHER and TENZING TUNDEN

The moratorium on IRS investigations and collections set forth by the People First Initiative will be ending soon on July 15.[i]  and very high wealth taxpayers should get ready for a little attention from the IRS.  If the moratorium is not extended, the IRS is poised to start the examination of several hundred high net […] Read More…

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SANDRA BROWN to Speak at the Upcoming ABA Virtual 2020 May Tax Meeting

We are pleased to announce that Sandra Brown will be speaking at the ABA Virtual 2020 May Meeting –When You Need to Disclose More Than Just a Tax Crime — on Tuesday July 14th at 2:00 p.m. – 3:00 p.m. (EST). Under the IRS voluntary disclosure practice, in exchange for a timely, accurate, and complete […] Read More…

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IRS Will Now Allow Taxpayers to E-File Amended Returns Due to COVID-19 By ROBERT HORWITZ and TENZING TUNDEN

For taxpayers heading into the extended tax season there is good news! The IRS will now allow E-filing of amended returns. The IRS published a notice on May 28, 2020 that amended returns for tax years beginning on or after January 1, 2017 can be filed electronically.[i]  Previously, amended returns had to be submitted manually […] Read More…

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Watch Out For Increased Tax Enforcement to Battle COVID-19—Good Idea or Money Grab? By STEVEN TOSCHER and TENZING TUNDEN © 2020

The Independent Commission for the Reform of International Corporate Taxation (“Commission”) is a group of leaders from around the world who believe that there is both an urgent need and an unprecedent opportunity to bring about significant reform of the international corporate taxation system.  The Commission is comprised of influential members from parliament, the United […] Read More…

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California Worker Classification Fight Continues But Expect Enforcement by JONATHAN KALINSKI

COVID-19 has placed much of our normal activities on hold.  It hasn’t, however, slowed down the maneuverings around California’s new worker classification law, known as AB5, which took effect January 1, 2020.  Just before the law took effect, the trucking industry won a major victory when Judge Benitez of the Southern District of California issued […] Read More…

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IRS Cracks Down on Tax Fraud by Creating a New Enforcement Office by STEVEN TOSCHER, SANDRA BROWN and LACEY STRACHAN

Comparing recent annual statistics of criminal investigations and  prosecutions by the Internal Revenue Service seems to suggest that the agency may be shifting resources away from criminal tax enforcement. In Fiscal Year 2019, the IRS Criminal Investigation Division initiated 2,485 investigations and recommended 1,893 prosecutions.  This continues a trend seen in recent years of declining […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to speak on Captive Insurance Companies: Where Are We Going After the IRS Victories

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CPAacademy webinar on Captive Insurance Companies: Where Are We Going After the IRS Victories, Tuesday, June 30 2020, 1:00 pm PST. The Internal Revenue Service (IRS) began sending contact letters in April […] Read More…

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It Still Lives!!  Recent Opinions in Two Willful FBAR Penalty Cases by ROBERT S. HORWITZ

It’s been so long since I have blogged about FBAR cases I almost forgot they even existed.  This is probably the effect of age.  But decisions in two recent cases show that FBAR willful penalty cases are still alive and reflect that courts are not blindly accepting the Government’s “pushing the envelope” theories.  Both cases […] Read More…

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Tax Court Update: Welcome to the Future- The Court Adopts Procedures for Remote Proceedings by JONATHAN KALINSKI

Like much of the country, the Tax Court is taking its business online, adopting procedures for remote proceedings on May 29 by issuing Administrative Order No. 2020-02.  Since March 11, when the Tax Court started cancelling trial sessions, court business has virtually stopped.  The Tax Court building in Washington, D.C. itself has been closed since […] Read More…

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NYU 12th Annual Tax Controversy Webinar – June 18-19, 2020

We are pleased to invite you to the NYU 12th Annual Tax Controversy Forum Webinar to be held June 18 and 19.  This year all registrations are complimentary.  As set forth below, Co-Chairs Bryan Skarlatos and Armando Gomez have assembled an all star group of Government speakers and it will be a great opportunity to learn […] Read More…

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MICHEL STEIN to speak on PPP Loans: Completing Loan Forgiveness Applications, Handling the Latest Q&As and other Recent Guidance

We are pleased to announce that our principal Michel Stein will be speaking at the upcoming Beverly Hills Bar Association webinar on PPP Loans: Completing Loan Forgiveness Applications, Handling the Latest Q&As and other Recent Guidance, Thursday, June 4, 2020, 3:00 pm-4:30 pm. Coronavirus Aid, Relief and Economic Security Act (CARES Act) brought us the […] Read More…

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