TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Steven Toscher along with Wazirah Allen, IRS-Criminal Investigations, Director of International Operations and Jeffrey Neiman will be speaking at the upcoming University of San Diego School of Law – Chamberlain International Tax Institute on Where There is Tariff Evasion, Tax Fraud is not Far Behind, February 16-17,2026, at Centro Internacional de Congresos en Mérida, México.

Tariff fraud often creates ripples beyond customs enforcement — leading directly into income tax fraud cases. This panel will discuss the important role the IRS Criminal Investigations is playing in the joint task force on combating tariff and customs fraud and will discuss real-world patterns where undervaluation, false invoicing, and transshipment schemes in customs filings lead to customs fraud and tax evasion. The panel will explore coordinated enforcement between the Department of Justice and various US and foreign investigative agencies. 

Click Here for More Information

For more information, please contact Steven Toscher at toscher@taxlitigator.com.

We’re pleased to announce that Sebastian Voth and Philipp Behrendt will be teaching this online course on Taxation of Digital Assets offered by UCLA Extension from February 10th through March 17th.

This online course prepares legal and tax professionals to plan, analyze, and implement compliant reporting for digital-asset transactions under current IRS rules. We concentrate on statutory and regulatory interpretation (e.g., §§1001, 1012, and §6045 broker reporting), classification of common and advanced transactions (swaps, wrapping/unwrapping, staking/mining, LP, lending), and practical reconciliation of Form 1099-DA with on-chain and exchange data. Participants will examine best practices, common pitfalls, audit-readiness techniques through case studies, and study relevant case law and current IRS guidance.

The aim and focus of the Course is to develop a practitioner-level command of the legal characterization and reporting mechanics of digital-asset activity, enabling participants to identify mismatches between broker reports and taxable events, advise clients effectively, and document defensible tax positions.

Click Here for Further Details

Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

Philipp Behrendt is an Associate at Hochman Salkin Toscher Perez P.C., licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Philipp is a Liaison to the Young Lawyer Committee for the ABA Tax Section’s Civil and Criminal Tax Penalties Committee and served on the Beverly Hills Bar Association’s Barristers Board of Governors from 2022 to 2023. Philipp is the Chair of the Beverly Hills Bar Association’s Tax Section and the Blockchain and Web3 Law Section.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

Social security and Medicare tax is based on wages paid employees under Internal Revenue Code (IRC) § 3101 and “net earnings from self-employment” under IRC § 1401.  “Net earnings from self-employment” is defined in IRC § 1402 and includes an individual partner’s “distributive share … of income or loss” of the partnership.  Section 1402 contains enumerated exclusions.  In 1976, Congress added subsection (a)(13) to § 1402, which reads:

(13) there shall be excluded the distributive share of any item of income or loss of a limited partner, as such, other than guaranteed payments described in section 707(c) to that partner for services actually rendered to or on behalf of the partnership to the extent that those payments are established to be in the nature of remuneration for those services.

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Robert S. Horwitz is a Principal at Hochman Salkin Toscher Perez P.C., former Chair of the Taxation Section, California Lawyers’ Association, a Fellow of the American College of Tax Counsel, a former Assistant United States Attorney and a former Trial Attorney, United States Department of Justice Tax Division.  He represents clients throughout the United States and elsewhere involving federal and state administrative civil tax disputes and tax litigation as well as defending clients in criminal tax investigations and prosecutions. In 2022 the Tax Section of the California Lawyers Association awarded him the Joanne M. Garvey Award for lifetime achievement in and contributions to the field of tax law. Additional information is available at http://www.taxlitigator.com.

For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com

On January 8, 2026, in response to alleged benefits fraud in Minnesota, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced the issuance of a Geographic Targeting Order (GTO) requiring all banks and money transmitters located in Hennepin County and Ramsey County, Minnesota, (Covered Businesses) to file reports with FinCEN of certain international fund transfers of $3,000 or more.

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Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9^th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits.

Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases on behalf of the United States.

Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance and criminal tax matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award, Chambers High Net Worth in Tax and Tax Fraud, and an honoree of the inaugural Lawdragon 500 Leading Global Tax Lawyers.

For more information, please contact Sandra R. Brown at brown@taxlitigator.com

We are pleased to announce that Jonathan Kalinski and Melissa Briggs have been elected Fellowsof the American College of Tax Counsel. Jonathan and Melissa join eight other members of our firm who are Fellows of the most prestigious group of tax lawyers in the United States.

The President of ACTC welcomed the new Fellows, noting that “we have had a vibrant and impactful year at the College, and we welcome our newest Fellows into our continuing mission of advancing sound tax policy and effective tax administration.”

Link to the Press Release

Jonathan Kalinski is a Principal of the law firm of Hochman Salkin Toscher Perez P.C. and specializes in both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. He handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski is a California Lawyers Association Taxation Section Executive Committee Member and an ABA Loretta Collins Argrett Fellowship Mentor.

For more information, please contact Jonathan Kalinski at kalinski@taxlitigator.com

Melissa Briggs is a Principal of the law firm of Hochman Salkin Perez P.C. where she represents clients in civil and criminal tax litigation as well as tax investigations. She has over twenty years of litigation experience, including over 16 years combined experience as an Assistant United States Attorney for the Central District of California, Tax Division, and an Appellate Attorney in the United States Department of Justice, Tax Division, Appellate Section.  

For more information, please contact Melissa Briggs at briggs@taxlitigator.com.

We are proud to announce that Evan Davis, a former white-collar federal prosecutor and current Principal of our firm, has been named to the inaugural list of Legal 500 City Elite’s top white-collar lawyers in Los Angeles. “US Elite emphasizes lawyers who are handling work at the top of the legal market in their respective cities.”

Legal 500 selects its elite lawyers after interviewing top practitioners, receiving peer feedback, and gathering evidence of key matters worked on by the ranked attorneys during the past year. 

Legal 500 is a London-based ratings company that focuses on how clients perceive their lawyers, including by measuring client satisfaction.  

Link to the Rankings

Evan Davis has been a Principal at Hochman Salkin Toscher Perez P.C. since November 2016. Mr. Davis handles federal and state criminal and civil tax investigations/exams, white-collar defense, cryptocurrency clients, and civil and criminal appellate matters including having litigated the In re Grand Jury attorney-client privilege matter before the US Supreme Court in 2023. 

Before joining the firm in 2016, Evan spent nearly 20 years with the US Department of Justice. He was first a civil trial attorney with DOJ’s Tax Division, then an Assistant U.S. Attorney in the C.D. Cal’s Tax Division handling civil and criminal tax cases and, finally, a criminal AUSA in the USAO’s Major Frauds Section handling white-collar, tax, and other fraud cases through jury trial and appeal. He served as the Bankruptcy Fraud coordinator, Financial Institution Fraud Coordinator, and Securities Fraud coordinator. His awards include the U.S. Attorney General’s Distinguished Service Award for Evan’s work on the $16 Billion RMBS settlement with Bank of America. He is also a Fellow of the American College of Trial Counsel.

For more information, please contact Evan Davis at davis@taxlitigator.com

As a member of the Planning Committee for the 2026 Tax Institute, hosted by USC Gould School of Law, I am excited to remind all that the Institute is taking place January 26–28, 2026, in Los Angeles and online.

This year’s program features three days of advanced tax programming across corporate, partnership, real estate, individual, enforcement, and estate planning topics. I hope you’ll consider joining us!

Also, very proud that four of our attorneys will be speaking on the following key topics:

Sandra R. Brown
A Conversation with the IRS Criminal Investigation Special Agent-In-Charge for the Los Angeles Field Office

Robert S. Horwitz and Philipp Behrendt
Employee Retention Credit Enforcement

Sebastian Voth
Valuation in Tax Cases: The Importance of Getting it Right

It will be a great program. The link for registration and finding out more about the Institute is below.

Click Here for More Information

Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9^th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits.

Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases on behalf of the United States.

Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance and criminal tax matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award, Chambers High Net Worth in Tax and Tax Fraud, and an honoree of the inaugural Lawdragon 500 Leading Global Tax Lawyers.

For more information, please contact Sandra R. Brown at brown@taxlitigator.com

Robert S. Horwitz is a Principal of Hochman Salkin Toscher Perez P.C. and has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Mr. Horwitz was previously a trial attorney, US Department of Justice Tax Division and an Assistant United States Attorney, Tax Division, Los Angeles. He was the 2022 recipient of the Joanne M. Garvey Award for lifetime achievement in and outstanding contributions to the field of tax law and the 2021 recipient of the Orange County Bar Association, Tax Chair Recognition award.

For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com

Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

Philipp Behrendt is a Principal at Hochman Salkin Toscher Perez P.C., licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Philipp is a Liaison to the Young Lawyer Committee for the ABA Tax Section’s Civil and Criminal Tax Penalties Committee and served on the Beverly Hills Bar Association’s Barristers Board of Governors from 2022 to 2023. Philipp is the Chair of the Beverly Hills Bar Association’s Tax Section and the Blockchain and Web3 Law Section.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

Hochman Salkin Toscher Perez P.C. is pleased to announce that Philipp Behrendt has been promoted to Principal. Before relocating to the United States, Philipp practiced as a tax lawyer in Germany for more than five years. He joined our firm four years ago and has built a practice focused on high-stakes tax controversy and examinations, with particular depth in matters involving digital assets and other technology-driven fact patterns.

Philipp is a frequent speaker on digital asset taxation, the use of AI in tax litigation, professional responsibility, and BBA partnership audits. He serves in various roles within the ABA Taxation Section of Civil and Criminal Tax Penalties Committee (Subcommittee for Administrative & Legislative Developments) and as Liaison to the Young Lawyers Committee. Philipp also chairs the Beverly Hills Bar Association’s Tax Section and its Blockchain & Web3 Section.

Philipp teaches Digital Asset Taxation as an instructor at UCLA Extension, authors and contributes to practitioner-facing publications and bar-association materials on tax administration and digital-asset issues and participates in professional and pro-bono service efforts (including a contributor to the Military State Tax Guide for California, ABA Virtual Settlement Week, and bar-comment work on emerging topics such as NFTs).

Philipp is grateful to the mentors, colleagues, and clients who have helped shape his path—and especially to his family for their constant support for understanding that a ‘quick call’ is best understood as a term of art.

For more information, please contact Philipp at behrendt@taxlitigator.com

We are pleased to announce that four of our attorneys will be speaking at the upcoming ABA Tax Section 2026 Midyear Tax Meeting, January 15-17, 2026 at the Marriott Marquis San Diego Marina on the following key topics:

Michel R. Stein, along with Jeff Oliver, Plante Moran, Rob Kovacev, Miller & Chevalier, and Alexandra Minkovich, Baker McKenzie will speak on What’s Up? Recent Developments and Pending Legislation on Tax Controversy Matters. Join us for a timely review of key cases, IRS rulings and legislation and pending legislation involving tax procedure, penalties, and litigation.

Evan J. Davis, along with Alexander Reid, BakerHostetler, Karen Kelly, Kostelanetz LLP and Joe Rillotta, Meadows Collier, will speak on Exploring the Ins and Outs of a Criminal Tax Investigation and the Particular Risks that Tax-Exempt Organizations Face.  Join us for a lively discussion of best practices for responding to and navigating a criminal tax investigation, the potential triggers of such an investigation, and the particular risks that tax-exempt organizations face with the IRS’s increased scrutiny of such clients.

Sebastian Voth, along with Professor Del Wright, Louisiana State University, Jennifer Schinke, Inland Counties Legal Services, and Hon. Emin Toro, United State Tax Court will speak on Anatomy of a Tax Motivated Transaction: Legal and Ethical Perspectives. This panel will provide a critical examination of today’s tax landscape, from highly engineered financial shelters designed for corporations and wealthy individuals to schemes targeting small businesses and low-income taxpayers.

Philipp Behrendt, along with Maria Critelli, Mayer Brown LLP, Rami Khoury, Taylor Nelson Amitrano LLP and Travis Thompson, Fennemore will speak on AI in Tax Controversy. This panel will discuss the ways in which AI is and will continue to impact tax controversy as well as ethical strategies for using AI in tax practice. 

Click Here to Register

Michel R. Stein, a principal of Hochman Salkin Toscher Perez P.C., is a nationally recognized tax attorney with nearly 30 years of experience in tax controversy and planning for individuals and business entities. He is widely respected for his ability to resolve complex and sensitive tax controversies before the Internal Revenue Service and the California Franchise Tax Board, including matters involving significant civil and criminal exposure, and is a trusted resource to clients and advisors navigating the most challenging areas of federal and state tax law. His commentary and insights have been featured in leading tax publications, webinars, and media outlets addressing emerging issues in tax enforcement and policy.

Mr. Stein has represented hundreds of clients in civil tax examinations, administrative appeals, and litigation before the U.S. Tax Court, U.S. District Courts, California Superior Court, and the U.S. Courts of Appeals. He routinely advises and defends clients in matters involving California Residency, Digital Assets and Cryptocurrency Investigations, High-Net-Worth Taxpayer Compliance and Examination, Domestic and International Tax Compliance, Voluntary Disclosures and Streamlined Filings, Challenges to Listed and Reportable Transactions, Partnership Tax and Audit Rules, Employment Tax and Worker Classification Issues, as well as tax controversies arising from Complex Real Estate and Business Transactions.  He began his legal career as an Attorney Advisor to Special Trial Judge Larry Nameroff of the U.S. Tax Court and is a Certified Specialist in Taxation Law by the State Bar of California.

For more information, please contact Michel R. Stein at stein@taxlitigator.com.

Evan Davis has been a Principal at Hochman Salkin Toscher Perez P.C. since November 2016. Mr. Davis handles federal and state criminal and civil tax investigations/exams, white-collar defense, cryptocurrency clients, and civil and criminal appellate matters including having litigated the In re Grand Jury attorney-client privilege matter before the US Supreme Court in 2023. 

Before joining the firm in 2016, Evan spent nearly 20 years with the US Department of Justice. He was first a civil trial attorney with DOJ’s Tax Division, then an Assistant U.S. Attorney in the C.D. Cal’s Tax Division handling civil and criminal tax cases and, finally, a criminal AUSA in the USAO’s Major Frauds Section handling white-collar, tax, and other fraud cases through jury trial and appeal. He served as the Bankruptcy Fraud coordinator, Financial Institution Fraud Coordinator, and Securities Fraud coordinator. His awards include the U.S. Attorney General’s Distinguished Service Award for Evan’s work on the $16 Billion RMBS settlement with Bank of America. He is also a Fellow of the American College of Trial Counsel.

For more information, please contact Evan Davis at davis@taxlitigator.com

Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

Philipp Behrendt is an Associate at Hochman Salkin Toscher Perez P.C., licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Philipp is a Liaison to the Young Lawyer Committee for the ABA Tax Section’s Civil and Criminal Tax Penalties Committee and served on the Beverly Hills Bar Association’s Barristers Board of Governors from 2022 to 2023. Philipp is the Chair of the Beverly Hills Bar Association’s Tax Section and the Blockchain and Web3 Law Section.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

We are pleased to announce that Michel R. Stein and Philipp Behrendt will be speaking at the upcoming CalCPA webinar on Cryptocurrency Tax Compliance: Tax Filing Requirements, New Form 1099-DA Broker Reporting Rules, and Managing IRS Examinations, on Tuesday, January 13, 2026, 9:00 a.m. – 10:30 a.m. (PST).

The program will provide a practical roadmap for examinations involving digital assets and will set forth an overview of the IRS’s guidance on digital asset transactions. This webinar will also examine how digital-asset compliance is changing, as Form 1099-DA broker reporting begins for transactions on or after January 1, 2025, and explain what taxpayers and their advisers should expect when payee statements start arriving in the 2026 filing season. The program will also address current developments under the new administration, alongside the IRS broader enforcement environment. 

Click Here to Register

Michel R. Stein, a principal of Hochman Salkin Toscher Perez P.C., is a nationally recognized tax attorney with nearly 30 years of experience in tax controversy and planning for individuals and business entities. He is widely respected for his ability to resolve complex and sensitive tax controversies before the Internal Revenue Service and the California Franchise Tax Board, including matters involving significant civil and criminal exposure, and is a trusted resource to clients and advisors navigating the most challenging areas of federal and state tax law. His commentary and insights have been featured in leading tax publications, webinars, and media outlets addressing emerging issues in tax enforcement and policy.

Mr. Stein has represented hundreds of clients in civil tax examinations, administrative appeals, and litigation before the U.S. Tax Court, U.S. District Courts, California Superior Court, and the U.S. Courts of Appeals. He routinely advises and defends clients in matters involving California Residency, Digital Assets and Cryptocurrency Investigations, High-Net-Worth Taxpayer Compliance and Examination, Domestic and International Tax Compliance, Voluntary Disclosures and Streamlined Filings, Challenges to Listed and Reportable Transactions, Partnership Tax and Audit Rules, Employment Tax and Worker Classification Issues, as well as tax controversies arising from Complex Real Estate and Business Transactions.  He began his legal career as an Attorney Advisor to Special Trial Judge Larry Nameroff of the U.S. Tax Court and is a Certified Specialist in Taxation Law by the State Bar of California.

For more information, please contact Michel R. Stein at stein@taxlitigator.com.

Philipp Behrendt is an Associate at Hochman Salkin Toscher Perez P.C., licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Philipp is a Liaison to the Young Lawyer Committee for the ABA Tax Section’s Civil and Criminal Tax Penalties Committee and served on the Beverly Hills Bar Association’s Barristers Board of Governors from 2022 to 2023. Philipp is the Chair of the Beverly Hills Bar Association’s Tax Section and the Blockchain and Web3 Law Section.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.