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SANDRA BROWN to speak at the NYU 78th Institute on Federal Taxation

We are pleased to announce that Sandra Brown, will be speaking on “From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Update” at this year’s NYU 78th Institute on Federal Taxation, Sunday, October 20th at the Grand Hyatt, New York and Sunday, November 10th at the Fairmont Hotel, San Francisco. Click Here for more […] Read More…

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MICHEL STEIN to speak at the NYU 78th Institute on Federal Taxation

We are pleased to announce that Michel Stein, will be speaking on “Ethics : When Are You Crossing A Line? Real-Life Ethical Issues in Everyday Tax Practice” at this year’s NYU 78th Institute on Federal Taxation, Thursday, November 14th at the Fairmont Hotel, San Francisco. Click Here for more information. How sure do you have to be before […] Read More…

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Is ‘Corporate America’ Looking at Increased Tax Enforcement? by STEVEN TOSCHER, SANDRA BROWN and GARY MARKARIAN

Is ‘Corporate America’ Looking at Increased Tax Enforcement? by STEVEN TOSCHER, SANDRA BROWN and GARY MARKARIAN

Recent changes in federal tax law, along with announcements from the Internal Revenue Service (IRS), have provided more than subtle signals that the federal taxing authorities are looking to increase their focus on big business, sometimes referred to as ‘Corporate America’. Signs can be gleaned from provisions included in the recently passed Taxpayer First Act […] Read More…

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UCLA 35th Annual Tax Controversy Conference – Message from STEVEN TOSCHER, Institute Chair

For THIRTY-FIVE YEARS the Annual Tax Controversy Institute has been among the preeminent tax conferences in the United States exclusively dedicated to tax controversy and tax litigation.  This year, I am again honored and privileged to serve as Chair of The Annual Tax Controversy Institute. Institute Chair Emeritus. The Institute was founded by Eugene “Gene” […] Read More…

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IRS Issues New Cryptocurrency Guidance

The IRS has published long-awaited guidance on the tax treatment of virtual currency transactions, five years after the agency issued its first official pronouncement on cryptocurrency taxation.   To read more Click Here.  

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UCLA 35th Annual Tax Controversy Conference

Plan on joining us on October 22, 2019 to help celebrate the 35th anniversary for one of the preeminent conferences exclusively dedicated to tax controversy and tax litigation.  The Annual Tax Controversy Institute provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience.  For […] Read More…

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Will There Be Greater IRS Scrutiny of Corporate Merger & Acquisition Transactions By STEVEN TOSCHER and TENZING TUNDEN

The Treasury Inspector General of Tax Administration (TIGTA) issued a report on September 5, 2019, which questioned the IRS Large Business and International Division’s (LB&I) strategy for examining corporate merger and acquisition (M&A) transactions. In the report, the TIGTA stated that the IRS’s approach to M&A transactions has been limited, separate, and distinct from one […] Read More…

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Law360 Quotes EVAN DAVIS: 4 Federal Tax Cases To Watch At The US Supreme Court

Law360 Quotes EVAN DAVIS: 4 Federal Tax Cases To Watch At The US Supreme Court

From challenging 30-year precedent that requires small-business owners to turn over self-incriminating tax records to determining the ownership of tax refunds among affiliated groups, the U.S. Supreme Court’s fall docket contains many interesting cases involving federal tax law. As the law stands, under Braswell the “collective entity doctrine” says corporations are treated differently from individuals […] Read More…

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JONATHAN KALINSKI to speak at the Beverly Hills Bar Association on AB 5 Aftermath: Tax, Employment, and Entertainment Fallout

We are pleased to announce that Jonathan Kalinski, along with David Pierce, Pierce Law Group, Greg Zbylut, Singer, Burke Zimmer, Lora Silverman, Ross & Silverman and Schuyler Moore, Greenberg Glusker, will be speaking on “AB 5 Aftermath: Tax, Employment, and Entertainment Fallout,” at Lawry’s The Prime Rib, Beverly Hills on Wednesday, October 2, 2019  at […] Read More…

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Court Confirms the IRS Can’t Get Blood from a Stone by EVAN J. DAVIS

For the most part, the deck is stacked in the IRS’s favor when it comes to enforcing administrative summonses.  It’s relatively easy for the government to show that it is entitled to enforcement of a summons through submitting a declaration from an IRS employee that states (often with no supporting facts): The investigation is being […] Read More…

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Your Small Business IRS Examination Might Take a Criminal Turn by JONATHAN KALINSKI

If you or your client are under examination by the IRS Small Business/Self-Employed (“SB/SE”) division, changes are your case will not be referred criminally.  Currently, criminal fraud referrals from the IRS civil divisions are only approximately 7% of IRS Criminal Investigations Division’s (“CI”) inventory.  Things, however, are changing, and taxpayers and their representatives should take […] Read More…

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California Doubles Down on Taxing the Underground Economy: What AB 1296 Could Mean for Tax Enforcement by SANDRA R. BROWN and TENZING TUNDEN

California is showing it is serious about taxing the underground economy. On September 13, Assembly Bill 1296 also known as “AB 1296”, was passed with unanimous consent by the California State Senate and California State Assembly.[1] If signed into law, AB 1296 will authorize California tax agencies to exchange intelligence, data, documents, information, complaints, or lead […] Read More…

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