We are pleased to announce that Sandra Brown along with Sharyn Fisk, IRS Office of Professional Responsibility, Caroline D. Ciraolo, and Bradley M. Seltzer will be speaking at the upcoming PLI Institute Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021 LA webinar, on “Balancing Tax Planning, Advocacy and Professional Ethics: The Rules That Every Tax Advisor Should Know” on Friday December 3, 2021, 1:10 p.m. – 2:30 p.m. (PST).


Ethics rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit; the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.

Click Here for more information.

We are pleased to announce that Steven Toscher along with Larry Campagna, Honorable Elizabeth Copland and Charles Muller III will be speaking at the upcoming University of Texas 69th Annual Taxation Conference webinar, on “What Does Enforcement Look Like Today?” on Thursday December 2, 2021, 1:30 p.m. – 3:00 p.m.(CST).


While Congress debates whether to fund more IRS enforcement, the Service continues to prioritize certain audit and criminal enforcement issues. Discuss areas of current IRS focus, such as John Doe summonses, conservation easements, captive insurance, employment taxes, passport restrictions, repatriation of assets, innocent spouse claims in the Tax Court, information return penalties, and regulation of return preparers. 

Click Here for more information.

We are pleased to announce that Sandra Brown will be speaking at the upcoming Freeman Law International Tax Symposium webinar, on “International Criminal Tax” on Friday, November 19, 2021, 9:25 a.m. – 10:15 a.m. (CST).

The United States and other countries have increased focus on investigating and prosecuting international tax crimes.  With the rise of supranational bodies, such as the OECD, as well as multi-lateral and bi-lateral information-exchange agreements, international criminal tax enforcement is on the rise.  We’ll discuss developments with respect to criminal tax enforcement in the international tax context.

Click Here for more information.

Coinbase will report its third-quarter earnings on Tuesday, likely giving more insight into its new offerings, such as its recently announced non-fungible token marketplace. The company, which is the largest crypto exchange in the U.S. by trading volume, could also announce new ventures as it expands further into financial services.

It likely won’t be a big deal for large exchanges like Coinbase, but it could drive some customers to buy and sell crypto on places Craigslist and the dark web, said Evan Davis, a tax attorney at Hochman Salkin Toscher Perez P.C., who represents crypto companies as clients.

Click Here for Article.

We are pleased to announce that Dennis Perez will be speaking at the upcoming Professional Advisory Network of the Motion Picture and Television Fund webinar, on “The California Exodus: How to Exit the State with Your Fortune Intact (or Not)” on Thursday November 11, 2021, 12:20 p.m. – 1:28 p.m. (PST).


Spurred by increasing taxes, crippling regulations and high-profile tech companies’ recent departures, many high net worth individuals are eyeing the exit door. Are states like Texas, Washington, Nevada, Florida and Tennessee truly greener pastures? And, what about lower net worth individuals? Join our panel of experts as we discuss the pros and cons surrounding the exodus buzz.


CLICK HERE for more information.

We are pleased to let you know that this year’s National Institute on Criminal Tax Fraud and Tax Controversy will be taking place in person in Las Vegas Nevada on December 8 through December 10, 2021. Yes — we are back live and look forward to seeing all of our colleagues up close and personal.


The ABA’s COVID-19 protocols will be in place and they can be located on the registration link below.

Attendees will need to affirm being vaccinated and or will be required to show a negative COVID test at registration on Wednesday and an updated test on Friday. The ABA wants to keep everyone safe. There will also be distance and mask protocols required by the Hotel.


The Institute is the yearly gathering of the Criminal and Civil Tax Controversy bars and brings together high-level Government representatives, judges, corporate counsel and private practitioners who engage in all aspects of tax controversy, civil tax litigation and criminal tax prosecution and defense.


We have an excellent line up of programs, including –


Our traditional Criminal Tax Workshop
Featuring Edward Robbins and Lacey Strachan


A Conversation with the Commissioner of Internal Revenue


Low Income Taxpayers: The Role of Unconscious Bias in Tax and Tax Collection (Diversity Credit)


Civil Workshop – Representing Taxpayers in Failure to File Cases


Civil and Criminal Enforcement Priorities
Featuring Sandra Brown


The Reorganized IRS: What It Looks Like andWhat It Means for Practitioners


Getting To “No”: What Works andWhat Doesn’t Work to Get the IRS and DOJ to Decline Prosecution


Jerry Feffer Annual Lunch


The View From the Tax Court


Trial Practice: How to Try Technical Tax Issues in Criminal Cases


Promoter Investigations: Penalties and Injunctions
Featuring Evan Davis


Sensitive Audits: Ethical Considerations


Ethical Issues in Collaboration in Precedent Setting Litigation


Smoke ‘Em if You Got ‘Em: What to do When Your State Legalizes Marijuana and the Federal Government Just Says No
Featuring Jonathan Kalinski

Common Yet Challenging Ethical Questions


Current Issues in Sentencing: Are We More Compassionate Now?


The Attorney-Client Privilege and Work Product Protection in Tax Cases –Developments and Best Practices


How to Try a Civil Tax Fraud Case


Cryptocurrency: Where Are We Today?
Featuring Michel Stein

CLICK HERE for more information.

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming Strafford webinar, on “IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals, and Litigation” on Thursday November 4, 2021, 10:00 a.m. – 11:50 a.m. (PST).


The IRS Large Business and International Division is auditing high net worth individuals and their related entities, including partnerships, S corporations, trusts, and private foundations. The Wealth Squad, a relatively new, highly-trained division of the IRS, is conducting these audits.


These examinations will target recently enacted and complex areas of taxation, including:

  • Section 199A Qualified Business Income Deduction
  • Section 163(j) Business Interest Deduction Limitation
  • Section 965 Repatriation of Previously Untaxed Foreign Earnings
  • Section 172 Net Operating Loss Deduction Refund Claims
  • Required foreign reporting of trusts, bank accounts, assets, etc.

Although targeting specific areas, these are comprehensive audits covering most aspects of a taxpayers’ tax return. Tax professionals working with high-wealth clients need to prepare for potential examinations and understand how to represent these taxpayers.


Listen as our panel of tax experts provides the latest information on these comprehensive audits, including the IRS selection process, information document requests, supporting documentation, audit adjustments, appeals, and litigation.


We are also pleased to announce that we will be able to offer a limited number of complimentary and reduced cost tickets for this program on a first come first serve basis. If you are interested in attending, please contact Sharon Tanaka at sht@taxlitigator.com. 

Click Here for more information.

We are pleased to announce that Sandra Brown will be speaking on “What’s New in Criminal Tax and Fraud Enforcement,” Thursday November 4, 2021, 3:45 p.m. – 5:00 p.m. (PST) and Jonathan Kalinski on Income Tax Hot Topics,” Friday, November 5, 2021, 3:30 p.m. – 5:00 p.m. (PST) at the upcoming 2021 Annual Meeting of the California Tax Bar and California Tax Policy webinar. Joining Ms. Brown will be Ryan Korner, Special Agent in Charge, IRS Criminal Investigation, Los Angeles Field Office, and Elizabeth Hadden, Deputy Division Counsel/Deputy Associate Chief Counsel, Criminal Tax, Office of Chief Counsel, IRS.  Joining Mr. Kalinski will be Cassidy Collins, Senior Counsel, SB/SE Division, Office of Chief Counsel, IRS.

The Conference features two and a half energy-packed days with an agenda of 33 educational courses and numerous networking opportunities tailored to corporate tax executives, attorneys, CPAs, financial planners, enrolled agents, government tax officials, legislators and staff, and law students.

Expert panels also cover the latest developments in other key areas of State and Local Tax, as well as Estate and Gift Tax, Tax Procedure and Litigation, and include important updates regarding the taxation of corporate and other business entities, international tax, tax legislation and tax policy.

Click Here for more information.

The recent article from the Huffington Post gives very high marks to Commissioner Rettig.  

Very proud of our former partner. 

Click Here for Article

We are pleased to announce that Dennis Perez, Sandra Brown and Cory Stigile will be speaking at the upcoming CalCPA webinar, “Advising High-Income Non-Filers, Voluntary Disclosure and Collection Issues”” on Tuesday, October 26, 2021, 9:00 a.m. – 10:00 a.m. (PST).

The IRS has increased their focus and efforts on high income taxpayers who haven’t filed their tax returns. The potential for significant penalties, limited voluntary disclosure options, and possible criminal prosecution forces tax counsel and advisers to grasp a complete understanding of applicable tax rules and procedures when representing high income taxpayers. The IRS issued IR-2020-34, which states the IRS “will step up efforts to visit high income taxpayers who in prior years have failed to timely file one or more of their tax returns.” The IRS now uses sophisticated data analytics to identify high income non-filers and tax preparers who promote false tax returns, as well as businesses with large amounts of unpaid employment taxes. Failure to file tax returns can have severe consequences. IRC 6651(a)(1) imposes substantial additions to tax for a failure to file a tax return.

Click Here for more information.

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