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New Enforcement Measures for the Employee Retention Credit Under the One Big Beautiful Bill by Steven Toscher, Robert S. Horwitz and Philipp Behrendt

New Enforcement Measures for the Employee Retention Credit Under the One Big Beautiful Bill by Steven Toscher, Robert S. Horwitz and Philipp Behrendt

On July 3, 2025, the House of Representatives narrowly passed the Republicans’ sweeping reconciliation package, the One Big Beautiful Bill, by a 218-214 vote, which President Trump signed on July 4. The legislation marks the most extensive tax package since the 2017 Tax Cuts and Jobs Act (TCJA), making many of the TCJA’s temporary provisions […] Read More…

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Supreme Court Rules, Again, on Tax Court Collection Due Process Jurisdiction by Robert S. Horwitz

Supreme Court Rules, Again, on Tax Court Collection Due Process Jurisdiction by Robert S. Horwitz

The IRS has the power to administratively collect an assessed tax liability through filing a notice of federal tax lien and through levying on a taxpayer’s property. Because the exercise of this power can have serious consequences for a taxpayer, Congress in Internal Revenue Code (“IRC”) §6330 gave taxpayers the opportunity to request a hearing before […] Read More…

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Michel R. Stein and Jonathan Kalinski to Speak at the Upcoming 17th Annual NYU Tax Controversy Forum

Michel R. Stein and Jonathan Kalinski to Speak at the Upcoming 17th Annual NYU Tax Controversy Forum

We are pleased to invite you to the  17th Annual NYU Tax Controversy Forumto be held June 26 and 27Westin New York, Times Square You do not want to miss this program. Two of our principals will be speaking on the following topics: Michel R. SteinChallenging Civil Penalties – Recent DevelopmentsJune 26 Jonathan KalinskiWho Pays? […] Read More…

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Hochman Salkin Toscher Perez 2025 Chambers USA Top Ranked – Tax Fraud and Tax Controversy

Hochman Salkin Toscher Perez 2025 Chambers USA Top Ranked – Tax Fraud and Tax Controversy

Once again, HOCHMAN SALKIN TOSCHER PEREZ P.C., along with Steven Toscher and Sandra R. Brown, have been recognized by Chambers and Partners, 2025 USA, for strength and expertise in the areas of Tax Fraud and Tax Controversy.  Chambers notes HOCHMAN SALKIN TOSCHER PEREZ P.C. is “a respected tax boutique noted for its handling of contentious tax matters. It has a hugely impressive track record in […] Read More…

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The J5 Sounds the Alarm: Fintech’s Double-Edged Sword in Global Tax Enforcement by Sandra R. Brown and Philipp Behrendt

The J5 Sounds the Alarm: Fintech’s Double-Edged Sword in Global Tax Enforcement by Sandra R. Brown and Philipp Behrendt

In a coordinated move that should command the attention of financial institutions, fintech startups, crypto platforms, and tax professionals alike, on June 10, 2025, the Joint Chiefs of Global Tax Enforcement (J5) released a trilogy of threat assessments aimed at exposing how emerging technologies are facilitating global financial crimes, including tax evasion. These reports, developed […] Read More…

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Michel R. Stein, Robert S. Horwitz and Melissa Briggs to Speak at Upcoming Strafford Webinar – International Tax Disputes, FBAR Violations, Form 3520, Excessive Fines

Michel R. Stein, Robert S. Horwitz and Melissa Briggs to Speak at Upcoming Strafford Webinar – International Tax Disputes, FBAR Violations, Form 3520, Excessive Fines

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Melissa Briggs will be speaking at the upcoming Strafford webinar, International Tax Disputes, FBAR Violations, Form 3520, Excessive Fines, Friday, June 20, 2025, 10:00 a.m. – 11:50 a.m. (PST). This webinar will analyze the most recent and relevant court cases affecting international taxpayers. […] Read More…

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Robert S. Horwitz to Speak at Upcoming Beverly Hills Bar Association Webinar – BBA Audits: What Tax Attorneys Need to Know

Robert S. Horwitz to Speak at Upcoming Beverly Hills Bar Association Webinar – BBA Audits: What Tax Attorneys Need to Know

We are pleased to announce that Robert S. Horwitz along with Jenni Black (Citrin Cooperman) will be speaking at the upcoming Beverly Hills Bar Association webinar, BBA Audits: What Tax Attorneys Need to Know webinar, Tuesday, June 3, 2025, 12:30 p.m. – 1:30 p.m. (PST). The webinar will provide an in-depth look at how the Bipartisan Budget Act (BBA) has […] Read More…

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Ten Hochman Attorneys Named to the Lawdragon 500 Leading Global Tax Lawyers

Ten Hochman Attorneys Named to the Lawdragon 500 Leading Global Tax Lawyers

We are honored and pleased to announce that ten (10) of our Principals have earned a distinguished place in the Lawdragon 500 Leading Global Tax Lawyers.  Our firm has one of the deepest and most experienced benches in the civil and criminal tax controversy field and we are proud of such recognition. Lawyers are selected for […] Read More…

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Michel R. Stein, Robert S. Horwitz and Sebastian Voth to Speak at Upcoming Strafford Webinar – Federal and State Residency Issues

Michel R. Stein, Robert S. Horwitz and Sebastian Voth to Speak at Upcoming Strafford Webinar – Federal and State Residency Issues

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Sebastian Voth will be speaking at the upcoming Strafford webinar, Federal and State Residency Issues webinar, Thursday, May 22, 2025, 10:00 a.m. – 11:30 a.m. (PST). This webinar will guide tax professionals and advisers on the latest IRS examination guidance on U.S. residency […] Read More…

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California Lawyers Association – 2025 DC Delegation

California Lawyers Association – 2025 DC Delegation

Link to DC Delegation Paper For more information, please contact Sebastian Voth at voth@taxlitigator.com. For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com

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Sandra R. Brown and Evan J. Davis to Speak at Upcoming Los Angeles County Bar Association Webinar – Dealing with IRS Criminal Investigation

Sandra R. Brown and Evan J. Davis to Speak at Upcoming Los Angeles County Bar Association Webinar – Dealing with IRS Criminal Investigation

We are pleased to announce that Sandra R. Brown and Evan J. Davis along with Terence Cuff (Loeb & Loeb) will be speaking at the upcoming Los Angeles County Bar Association Dealing with IRS Criminal Investigations webinar, Wednesday, May 21, 2025, 12:00 p.m. – 1:00 p.m. (PST). The panel will discuss challenges and strategies when dealing […] Read More…

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Steven Toscher and Philipp Behrendt to Speak at Upcoming ABA May Meeting

Steven Toscher and Philipp Behrendt to Speak at Upcoming ABA May Meeting

We are pleased to announce that Steven Toscher and Philipp Behrendt will be speaking at the upcoming ABA May Meeting being held at the Marriott Marquis, Washington D.C., May 8-10, 2025. The May Tax Meeting is the Section’s largest and the premier event for lawyers interested in all aspects of tax law. Join us in Washington, […] Read More…

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