TAXLITIGATOR Blog

Court Holds Dynamex ABC Test Does Not Apply for Unemployment Insurance Purposes Pre-2020, but Employer Still Loses BY: ROBERT HORWITZ and TENZING TUNDEN

In September 2019, California enacted Assembly Bill 5, which codified the three part “ABC test” of Dynamex Operations West Inc. v. Superior Court, 4 Cal.4th 903 (2018), to determine whether workers are employees and not independent contractors.  Under the ABC test a worker is presumed to be a common law employee unless the hiring entity […] Read More…

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Join STEVEN TOSCHER in his recent podcast on IBFD Tax Takes: News and Views, where he is interviewed by Stu Gibson of IBFD on the current state of the taxation of cryptocurrency and IRS enforcement. Things are heating up.

The views: Steve Toscher (Managing Principal, Hochman Salkin Toscher Perez) and Stuart Gibson (Chief Editor, Global News and US, IBFD) discuss the main tax issues you should be aware of regarding virtual currency. They summarize the IRS’s public guidance on virtual currency, efforts within the United States to advise taxpayers of their reporting obligations, as […] Read More…

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STEVEN TOSCHER and EVAN DAVIS to Speak at Upcoming ABA Webinar A New Regime of Transparency: Anti-Money Laundering and Corporate Transparency Acts of 2020 and Expansion of Cryptocurrency Reporting

We are pleased to announce that Steven Toscher will be moderating and Evan Davis will be speaking at the upcoming ABA webinar, “A New Regime of Transparency: Anti-Money Laundering and Corporate Transparency Acts of 2020 and Expansion of Cryptocurrency Reporting” on Tuesday, April 27, 2021, 1:00 p.m. (EST), 10:00 a.m. (PST).Joining the panel will be Andrew Winerman, Acting Deputy Associate Director of […] Read More…

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The Good, the Bad and the Ugly FBAR Style by Robert Horwitz

What does the title of one of Sergio Leone’s great Clint Eastwood westerns have to do with Foreign Bank Account Reports (known in the trade as “FBARS”) and FBAR penalties.  Two significant court of appeal opinions and a district court opinion involving the FBAR penalty were issued recently (United States v. Boyd, __ F.3d __, […] Read More…

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The Good, the Bad and the Ugly FBAR Style Part 2 or A Fistful of Dollars (that the Government Wants) by ROBERT HORWITZ

“When a man’s got money in his pocket he begins to appreciate peace.” The Man With No Name Why start with a quote from one of Sergio Leone’s great Clint Eastwood westerns, A Fistful of Dollars.   It is more peaceful to have money in your pocket, or at least close by in a domestic financial […] Read More…

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The IRS Confirms Its “Great Eye” is Firmly Fixed on Cryptocurrency, Announcing “Operation Hidden Treasure” By EVAN DAVIS

In the Lord of the Rings saga, the antagonist is a disembodied entity called Sauron who was represented by a flame-filled “Great Eye.”  Sauron’s Great Eye had powerful vision when fixed upon his rivals, but even this powerful eye was unable to see unaided into the thoughts of humans.  Fans of the LOTR movies know […] Read More…

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STEVEN TOSCHER quoted in Forbes article on IRS Cryptocurrency Enforcement

On March 30, the Department of Justice, Tax Division, filed a petition for leave to serve a “John Doe” summons on Payward Ventures, also known as “Kraken,” requesting account information for all United States taxpayers who held accounts there with the equivalent value of $20,000 or more in cryptocurrency for any one year from 2016 […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak on Cryptocurrency Tax Compliance in the Post-$50,000 Bitcoin World

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Strafford webinar, “Cryptocurrency Tax Compliance in the Post-$50,000 Bitcoin World: Tax Filing Requirements, Managing IRS Examinations” on Thursday, April 22, 2021, 10:00 a.m. – 11:30 a.m. (PST), 1:00 p.m. – 2:30 p.m. (EST).  This CLE/CPE webinar […] Read More…

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The Current IRS Voluntary Disclosure Practice by SANDRA BROWN

We are very pleased to announce that Sandra Brown is featured in  this month’s  Los Angeles Lawyer discussing the IRS Voluntary Disclosure Practice. Check out the current state of the practice and Sandra’s insights. The tax system of the United States is often described as one of “voluntary compliance.”  However, there is little about the […] Read More…

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IRS Will Continue to Emphasize High-Income Taxpayers In the Collection of Delinquent Taxes by STEVEN TOSCHER, DENNIS PEREZ and TENZING TUNDEN

IRS Will Continue to Emphasize High-Income Taxpayers In the Collection of Delinquent Taxes by STEVEN TOSCHER, DENNIS PEREZ and TENZING TUNDEN

The Internal Revenue Service will continue its focus on collecting delinquent taxes from the wealthiest taxpayers. The Treasury Inspector General for Tax Administration (TIGTA) recently published a report on the IRS efforts to collect delinquent taxes from wealthy taxpayers. This is the second report by  TIGTA on the IRS attempts to increase compliance of this […] Read More…

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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak on Handling Partnership Examinations

We are pleased to announce that Michel Stein, Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Spidell webinar, “Handling Partnership Examinations” on Thursday, March 25, 2021, 10:00 a.m. – 12:00 p.m. (PST). This webinar will cover practical considerations for partners and advisers to partnerships now operating under the new partnership audit regime. […] Read More…

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Journal of Tax Practice and Procedure – The News from the FBAR Front Isn’t All Bad, It Only Seems That Way Sometimes by ROBERT HORWITZ

“Friend of the JTPP, Robert S. Horowitz shares an update on penalties in The News from the FBAR Front Isn’t All Bad, It Only Seems That Way Sometimes. It’s good to hear the phrase “non-willful FBAR cases” even if it is a rare case. It seemed for a while that IRS wasn’t able to find […] Read More…

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