TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

For years, the IRS has told taxpayers to report digital asset dispositions like any other property transaction – compute gain or loss, determine holding period, and report the result on the return. The problem was practical, not theoretical: for digital assets, the Government often lacked what made securities reporting effective for decades – third-party information reporting that arrives in the taxpayer’s mailbox and in the IRS’s matching system at the same time.

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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.