Did you or your client move to Puerto Rico, or are you considering a move? Many Americans have taken advantage of the very favorable tax treatment available to Puerto Rican residents, but not all of them have complied with the strict requirements for favorable tax treatment. But, related to the number of Americans who claim Puerto Rican tax residency, the small handful of civil and criminal tax matters may have given taxpayers the impression that the IRS either doesn’t care or can’t get its act together to address any improper claims of Puerto Rican residency. But that appears to be changing, thanks to a Government Accountability Office (GAO) audit that laid bare the IRS’s inadequacies.
Steven Toscher is the Managing Principal of the law firm, who specializes in civil and criminal tax controversy and litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization, a Fellow of the American College of Tax Counsel and has received an “AV” rating from Martindale Hubbell. Mr. Toscher serves as Co-Chair of the UCLA Tax Controversy Institute and Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference. Mr. Toscher is a frequent lecturer and author on tax controversy and litigation topics and is a co-author of the BNA Portfolio, Tax Crimes. Mr. Toscher was the 2018 recipient of the Joanne M. Garvey Award, given annually to recognize lifetime achievement and outstanding contributions to the field of tax law by a senior member of the California tax bar. Mr. Toscher is also the recipient the USD School of Law Richard Carpenter Excellence in Tax Award. In 2024 Mr. Toscher was the recipient of the prestigious Jules Ritholz Memorial Merit Award presented by the Civil and Criminal Tax Penalties Committee of the Taxation Section of the American Bar Association, recognizing tax lawyers who have demonstrated outstanding dedication, achievement and integrity in the field of civil and criminal tax controversies.
For more information, please contact Steven Toscher at toscher@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. He is also a Fellow of the American College of Trial Counsel
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.
For more information, please contact Evan Davis at davis@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, a Liaison.
For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.
TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 
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