Our Firm Michel R. Stein

stein@taxlitigator.com Phone: (310) 281-3248
Fax: (310) 859-1430 Download Vcard

MICHEL R. STEIN is a principal at Hochman Salkin Toscher Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations.  For more than 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.

Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise.

Throughout his career, Mr. Stein has represented thousands of individual, business and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayer’s and their advisors around the world.

Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.

Honors and Affiliations:

  • Attorney-Adviser to the U.S. Tax Court Honorable Judge Larry L. Nameroff
  • Certified Specialist in Taxation Law State Bar of California, Board of Legal Specialization
  • Adjunct professor Golden Gate University, Graduate School of Taxation
  • UCLA Attorney Assistant Training Program Instructor on Estate Planning and Probate
  • 2010, 2011 2012, 2013, 2014, 2015, 2017, 2018 and 2019 Distinctions of Southern California Super Lawyer by Law & Politics, recognized and published in Los Angeles Magazine
  • 2005, 2006 and 2007 Southern California Super Lawyer Rising Star Distinction by Law & Politics, recognized and published in Los Angeles Magazine

Education:

  • NYU School of Law (LL.M. in Taxation)
  • University of California, Hastings College of the Law (J.D.)
  • California State University, Northridge, (B.S. Accounting)

Publications:

Mr. Stein has extensively published and co-authored articles in the field of tax law, including.

  • “Cryptocurrency – FinCEN and the Emerging Threat to Discovery of Worldwide Hidden Wealth,” August-September, 2018, Journal of Tax Practice and Procedure.
  • “The Eighth Amendment Limits on FBAR Penalties – Common Sense Limitations Becomes a Legal Reality,” June-July, 2018, Journal of Tax Practice and Procedure.
  • “Cryptocurrency and IRS Enforcement – Get Ready for Uncle Same to Look into Your Digital Wallet,” February-March, 2018, Journal of Tax Practice and Procedure
  • “Panama Papers: Tax Evaders Beware,” Summer 2016 Best Lawyers
  • “The Continuing Evolution of FBAR Enforcement,” April-May, 2016 Edition of CCH Journal of Tax Practice and Procedure
  • “Recent Wealth Transfer Developments,” Chapter in the USC Gould School of Law’s 2013 Major Tax Planning
  • “FBAR Examination, Appeals and Collection Procedures in the Post-Amnesty World,” January 2012 edition of CCH Journal of Tax Practice and Procedure
  • Contributed insights and answers to CCH (a Wolters Kluwer Business) publication, 2010 Tax Legislation, “Patient Protection and Affordable Care, Health Care Reconciliation”
  • “Foreign Bank Secrecy – No More – A New Era of International Tax Enforcement,” Chapter in the USC Gould School of Law’s 2009 Major Tax Planning Edition,
  • “FBAR Enforcement – Five Years Later,” July 2008 edition of CCH Journal of Tax Practice and Procedure
  • “FBAR – An Update”, May 2006 CCH Journal of Tax Practice and Procedure
  • “Criminal Enforcement of FBAR Filing Requirements,” June 2006 Law Journal Newsletters, Business Crime Bulletin
  • “FBAR Enforcement is Coming!,” January 2004 edition of CCH Journal of Tax Practice and Procedure

Presentations:

Mr. Stein frequently lectures on many topics throughout the country. His more recent speaking engagements include:

  • Taxation of Cannabis: Overcoming Tax Challenges in Marijuana, Business Operations, Key Planning Techniques, May, 2019
  • The Block Chain Gang: Criminal Enforcement & Tax Reporting for Cryptocurrencies & ICO Tokens, Strafford, March, 2019
  • CalCPA Ventura Discussion Group, International Tax Compliance, including FBAR Reporting, New Disclosure Guidelines, Audits, Appeals and Litigation, January, 2019
  • CalCPA Ventura Discussion Group, New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment, January, 2019
  • New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatments, myLawCLE, January 2019
  • Encore presentation, Form 5471 Substantial Compliance Rules: IRS International Practice Unit Guidance, Strafford, January, 2019
  • How to Persuade: Tips on Trial Practice Techniques, ABA Criminal Tax Fraud, December, 2018
  • Federal and State Tax Residency Rules: New IRS Examination Guidance and Navigating State Tax Regulations, Strafford, December, 2018
  • Tax Reporting of Bitcoin and Other Cryptocurrency: Calculating Basis, Income and Gain, 5th Annual New England Representation Conference, November, 2018
  • Form 5471 Substantial Compliance Rules: IRS International Practice Unit Guidance, Strafford, November, 2018
  • New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment, Strafford, October, 2018
  • Tax Enforcement Frontier: Crypto Currencies, STEP Los Angeles, July, 2018.
  • Tax Reporting of  Bitcoin and Other Cryptocurrency: Calculating Basis, Income and Gain, Strafford, June, 2018.
  • Cryptocurrency and IRS Tax Enforcement, Beverly Hills Bar Association, May, 2018.
  • New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements & Exchange Treatment, Strafford, May, 2018.
  • International Tax Law Enforcement, San Fernando Valley Bar Association, March, 2018.
  • Encore Presentation, New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment, April, 2018
  • New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment, February, 2018.
  • Hot Topics in IRS Enforcement Tips from the Tax Trenches, Clear Law Institute, August, 2017.
  • Offshore Voluntary Disclosure Program (OVDP): A 2017 Outlook LIVE Webcast, The Knowledge Group, July, 2017.
  • FBAR Update: Mastering FinCen Form 114, New Deadlines, Extension, Penalty Resolution and Waiver Provisions, Strafford Webinar, February, 2017
  • FBAR Update: Mastering FinCen Form 114, New Deadlines, Extension, Penalty Resolution and Waiver Provisions, Strafford Webinar, February, 2016
  • A Walk on the Wild Side – IRS Examinations of Foreign Account Holders & OVDP, UCLA 31st Annual Tax Controversy Institute, October 2015
  • Tax Practice & Procedure Monthly Roundtable, Federal Bar Association, June 2015
  • Federal Bar Association Section on Taxation, IRS Offshore Initiative Update, June 2015
  • CalCPA LA Hollywood/Beverly Hills International Tax Update and Issues for CPAs and Their Clients, May 2015
  • Offshore Tax Enforcement Update, Tips from the Tax Trenches, UCLA 30th Annual Tax Controversy Institute, October, 2014
  • CalCPA CCH Ventura CPA Foreign Accounts & IRS Enforcement, August 2014
  • U.S. Global Tax Enforcement Priorities, ABA Center for Professional Development, June, 2014
  • FBAR Compliance and Enforcement Update for Foreign Accountholders Living in the U.S. and Abroad, March, 2014 Audio Seminar for CCH (A Wolters Kluwer Business)
  • FBARs What Taxpayers With Asian Accounts Should Know From Government Enforcement in Switzerland & the Middle East, March, 2014 CalCPA Pasadena Discussion Group
  • Civil to Criminal Undeclared Foreign Financial Accounts – Tips from the Tax Trenches, UCLA 29th Annual Tax Controversy Institute, October, 2013
  • International Tax Enforcement Update,  LACBA Taxation Section 2013 Tax Night, February, 2013
  • IRS Enforcement Foreign & Domestic Priorities, Penalties and Practical Advice, January, 2013 USC Gould School of Law
  • Dual Citizenship and FBAR Issues, Orange County Chapter of Society of Trust and Estate Practitioners (STEP), November, 2012
  • Voluntary Disclosure Demystified – Tips from the Tax Trenches, UCLA 28th Annual Tax Controversy Institute, October, 2012
  • FBAR and FATCA update: Latest Foreign Account Reporting Developments, September, 2012 Audio Seminar for Strafford
  • Foreign Financial Asset Reporting Requirements, Audio Seminar for CCH (A Wolters Kluwer Business), May, 2012
  • Recent Developments in Reporting and Litigation for Foreign Bank and Financial Asset Accounts” CalCPA Discussion Group Business Managers, May, 2012
  • FBAR/FATCA Compliance Update,  Audio Seminar for CCH (A Wolters Kluwer Business), February, 2012
  • Latest Developments on Foreign Bank Account Changing Requirements, Hawaii Tax Institute, December, 2011
  • 2012 IRS Enforcement Priorities, Ventura County Society of CPAs, December, 2011
  • Reporting Cash Transactions and Foreign Financial Accounts (FBAR), August, 2011, IRS Nationwide Tax Forum in San Jose, California
  • Panelist, 2011 Entertainment Industry Conference,  CalCPA Education Foundation – Tax Update, June 2011
  • IRS Audit Issues, Hot Topics and Current Enforcement Priorities and Strategies, May, 2011 California Society of CPA’s, Hollywood/Beverly Hills Discussion Group
  • FBAR Compliance Update, live Audio Seminar for CCH (A Wolters Kluwer Business), February 2011
  • 2011 IRS Offshore Voluntary Disclosure Initiative (“OVDI”),  live Audio Seminar for CCH (A Wolters Kluwer Business), February, 2011
  • FBARs; Where are we now?, CalCPA Pasadena Discussion Group, February, 2011
  • Best of CLE on the topic of Current Developments in IRS Tax Controversies and Enforcement Initiatives in the Global Economy, January, 2011
  • IRS Enforcement: Worker Classification, American Employment Law Council 18th Annual Conference in Naples, Florida,November, 2010
  • IRS Enforcement: Worker Classification and the NRP, Atlanta Tax Forum, September 2010
  • Foreign Bank Account Reports (“FBAR”) – One Year Later, CalCPA Education Foundation, Los Angeles Taxation Committee, July, 2010
  • Foreign Bank Account Reporting – What’s Next?, Patentax Talk lecture series, July 2010
  • Foreign Account and Compliance Update, June, 2010 Audio Seminar for CCH (A Wolters Kluwer Business), June 2010
  • Latest Developments in Foreign Bank Account Reporting, San Fernando Valley CPA Discussion Group for the LA Chapter of the California Society of CPAs, March, 2010

Bar Admittance:

  • U.S. Tax Court
  • U.S. District Court for the Central and Northern Districts of California
  • U.S. Court of Federal Claims
  • U.S. Court of Appeals for the Ninth Circuit

Member:

  • Past-Chair, State Bar of California, Tax Procedure & Litigation Committee
  • Past-Chair, State Bar of California, Tax Law Advisory Commission, Board of Legal Specialization
  • Past-Chair, State Bar of California, Young Tax Lawyers Committee
  • Past-Chair, L.A. County Bar Association, Young Tax Lawyers Committee
  • American Bar Association, Taxation Section
  • California State Bar Association, Taxation Section
  • Beverly Hills Bar Association Taxation Section
  • Los Angeles County Bar Association Taxation Section
  • Association of Tax Counsel, Los Angeles



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