HOCHMAN SALKIN TOSCHER PEREZ, PC, is internationally recognized for excellence, integrity and the ability to achieve the best possible results for our clients throughout the world. Our experienced tax lawyers have outstanding tax-related credentials and are routinely recognized as leaders in handling all aspects of sophisticated tax controversies and criminal tax matters.
The firm specializes in expediting favorable resolution strategies for administrative tax controversies and tax disputes with the federal, state and local taxing authorities, federal and state civil tax litigation, defense of criminal tax investigations and prosecutions, white collar criminal defense, and family wealth transfers and related planning opportunities. We routinely handle representations involving complex and sensitive issue tax examinations and administrative appeals, voluntary and “scorched earth” tax collection problems, responding to summonses and subpoenas, and trials and appeals before all Federal courts. We enjoy an extensive history of successfully resolving the most sensitive, complex tax matters for our clients in the most efficient, cost-effective manner.
The firm’s extensive tax expertise includes a strong emphasis in numerous areas of civil tax disputes as well as defending criminal tax investigations and prosecutions. Our tax lawyers are routinely involved in complex civil tax examinations on behalf of wealthy individuals and closely held entities as well as large corporations involving both domestic and foreign tax related issues. The firm is internationally recognized as a leader in the representation of taxpayers throughout the world in matters involving the ongoing, extensive efforts of the US government to identify undeclared interests in foreign financial accounts, voluntary disclosures (OVDP Streamlined Procedures and otherwise), sensitive issue civil tax examinations, criminal tax investigations and prosecutions.
The firm has represented literally hundreds and hundreds of US taxpayers participating in various IRS Offshore Voluntary Disclosure Programs (OVDP) Streamlined Procedures and other forms of voluntary disclosures regarding foreign financial account values far exceeding billions of dollars, in the aggregate. The firm has also represented numerous taxpayers involved in Grand Jury criminal tax investigations, criminal tax prosecutions and, when beneficial for the client, the effective negotiation of plea agreements involving the alleged misuse of foreign entities to conceal legal and beneficial interests in foreign financial accounts and assets.
Few other firms have the similar firm-wide background and experience of our tax lawyers derived from positions at the U.S. Department of Justice, Internal Revenue Service, U.S. Tax Court and private practice. Coupled with strong working relationships with these government agencies, we are fully capable to provide effective representation of our clients when facing the most complex or sensitive tax-related matters.
The firm authored the Tax Management Portfolio “Tax Crimes” (Pub. 636) (2d.) published by the Bureau of National Affairs. Several of the firm’s attorneys gained their initial experience while working as Attorney-Advisors for the United States Tax Court in Washington, D.C., as tax prosecutors for the Office of the United States Attorney for the Central District of California, as trial attorneys for the Tax Division of the United States Department of Justice in Washington, D.C. or the Office of District Counsel of the Internal Revenue Service. Some have been appointed to serve as Chair of the Internal Revenue Service Advisory Council (IRSAC), the Advisory Board for the California Franchise Tax Board and the Advisory Council for the California State Board of Equalization.
Representatives of the firm routinely Chair conferences focused on offshore voluntary disclosures and defensive strategies to government examinations and criminal investigations and serve on prestigious committees of national, state and local bar and accounting associations and many are regular contributors to leading journals and publications involving tax matters. With respect to tax-related matters, few firms have the resources, relationships, expertise and collective experience offered by HOCHMAN SALKIN TOSCHER PEREZ, PC.Members of the firm have authored numerous articles which are available under “Publications,” a representative sample include:
- IRS Offshore Voluntary Disclosure Program: Opt-Outs, a Revised FBAR and Rescissions of Pre-Clearance Letters by Criminal Investigations
- IRS Provides Updated Guidance Regarding Offshore Voluntary Disclosure Program
- GAO to IRS: Pursue Quiet Disclosures and First Time FBAR Filers
- Evaluation of an IRS Undisclosed Offshore Account IDR
- Lichtenstein Accounts, German Spies and Now the IRS?
- Proving Willfulness in Civil FBAR Cases
- When Penalties Are Excessive – The Excessive Fines Clause as a Limitation on the Imposition of the Willful FBAR Penalty
- What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account?
- The Fifth Amendment FBAR Lives!