We are pleased to announce that Steven Toscher Michel R. Stein and Robert Horwitz will be speaking at the upcoming Strafford IRS Crackdown on Abusive Basis-Shifting Transactions webinar, Wednesday, November 13, 2024, 10:00 a.m. – 11:30 a.m. (PST).
This webinar will provide tax professionals with comprehensive guidance on recent IRS focus on abusive basis-adjustments transactions and navigating applicable tax rules and IRS examinations. We will discuss the potential application of the rules and proposed regulations, IRS challenges to surrounding basis adjustments, Notice 2024-54 and forthcoming regulations addressing basis-shifting transactions for partnerships and related parties, and Rev. Rul. 2024-14 and the economic substance doctrine, as well as offer practical tips to avoid costly and unanticipated tax consequences.
We are pleased to announce that Michel R. Stein and Robert Horwitz will be speaking at the upcoming CalCPA Partnership Examination Rules Under the Bipartisan Budget Act webinar, Tuesday, November 12, 2024, 9:00 a.m. – 10:30 a.m. (PST).
This webinar will cover practical considerations for partners and advisers to partnerships now operating under the new partnership audit regime. We will review the latest guidance, explain partnership audit adjustments, and make recommendations for steps to take in light of the implementation of this new regime.
Michel R. Stein is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil and criminal tax matters where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance tax matters. Mr. Stein is a frequent lecturer at national and regional conferences on topics, including Global High Wealth examinations, cryptocurrency, sensitive tax compliance matters, IRS examinations, International tax issues and state and federal residency and worker classification matters. For more information, please contact Michel R. Stein at stein@taxlitigator.com.
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. He was the 2022 Joanne M. Garvey Award for lifetime achievement in and contribution to the field of tax law by the Taxation Section of the California Lawyers Association. For more information contact Robert Horwitz at horwitz@taxlitigator.com.
We are pleased to announce that Steven Toscher, Michel R. Stein, Robert Horwitz, Jonathan Kalinski and Sebastian Voth will be speaking on the following topics at the upcoming California Lawyers Association 2024 Annual Meeting of the Tax Bar and Tax Policy Conference being held at the Anaheim Hilton Hotel on November 6-8, 2024.
How to Handle Sentencing in Federal Tax Cases Steven Toscher
BBA Audits and Appeals Michel R. Stein
Basis Shifting in Partnerships: Preparing for IRS Challenge Robert Horwitz
Taxation of Gambling and Forfeiture Jonathan Kalinski
Steven Toscher is a Principal of the law firm Hochman Salkin Toscher Perez P.C., where he specializes in civil and criminal tax controversy and litigation. He 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 was the 2018 recipient of the Joanne M. Garvey Award. The award is 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 the 2024 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. The Jules Ritholz Memorial Merit Award recognizes 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.
Michel R. Stein is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil and criminal tax matters where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance tax matters. Mr. Stein is a frequent lecturer at national and regional conferences on topics, including Global High Wealth examinations, cryptocurrency, sensitive tax compliance matters, IRS examinations, International tax issues and state and federal residency and worker classification matters. For more information, please contact Michel R. Stein at stein@taxlitigator.com.
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. He was the 2022 Joanne M. Garvey Award for lifetime achievement in and contribution to the field of tax law by the Taxation Section of the California Lawyers Association. For more information contact Robert Horwitz athorwitz@taxlitigator.com.
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. For more information, please contact Jonathan Kalinski at kalinski@taxlitigator.com.
Sebastian Voth is a Principal of the law firm of 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 more than 15 years as an attorney for 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. For more information, please contact Sebastian Voth at voth@taxlitigator.com.
We are pleased to announce that Sandra R. Brown will be honored at the Toast to Women in Tax by the 2024 Annual Meeting of the Tax Bar and Tax Policy Conference taking place November 7, 2024 in Anaheim California.
This honor is given to women attorneys and tax practitioners who have achieved professional excellence in their field of practice. This will also be a valuable time to network, get involved with the Women in Tax Standing Committee.
Sandrais a Principal of the law firm Hochman Salkin Toscher Perez P.C., where she specializes in criminal tax investigations, grand jury matters, litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.
Prior to entering private practice, 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. During her 27 years as a trial lawyer, she personally handled over 2,000 tax cases on behalf of the United States before the United States District Court, the Ninth Circuit Court of Appeals, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel, and the California Superior Court. Included in those cases are two U.S. Supreme Court decisions and a multitude of published 9th Circuit decisions.
We are pleased to announce that Dennis Perez, Evan Davis and Jonathan Kalinski will be speaking at the upcoming CalCPA What to Do When the Criminal Investigation Division Shows Up webinar, Friday, October 18, 2024, 9:00 a.m. – 10:30 a.m. (PST).
In September 2020, the IRS created the Office of Fraud Enforcement (OFE) to improve fraud detection and development of fraud cases to address areas of high fraud and risks noncompliance with the tax laws. With this new office, the IRS emphasized its focus on case selection when determining to pursue civil fraud penalties and the appropriate cases to refer to IRS-Criminal Investigation (CI). With an $80 billion budget over the next ten years and a focus on hiring and enforcement and the IRS’s increased ability to analyze data, the increased attention to non-compliance taxpayers is almost certain. This program’s learning objectives will help you better recognize what may be a sensitive audit and when intrusive demands for evidence and your client’s interview, an often “touchy issue” may signal issues beyond a tax deficiency.
We are now less than a month away from celebrating the 40th Anniversary of the UCLA Extension Tax Controversy Institute. Following four decades of our tradition of presenting stellar topics and top-tier speakers which has made the Institute the annual “can’t miss tax controversy program,” this year is sure to be one of our best ever!
The Institute will also have the Taxpayer Advocate Service (TAS) available on-site to assist with unresolved IRS tax issues during this year’s conference. Appointments must be scheduled in advance. To schedule an in-person appointment, please contact the Los Angeles office and mention “UCLA Extension Tax Controversy Institute Problem Solving Day” along with your name and phone number. You can reach Local Taxpayer Advocate Luis Tejeda by leaving a message at (213) 372-4388. Also, below is additional information.
We are pleased to announce that Jonathan Kalinski along with Ani Galyan (Galyan Law a P.C.), Michael McGuinness (CDTFA), and Leslie Ang (CDTFA) will be speaking at an upcoming Beverly Hills Bar Association on 2024 California Cannabis Tax Update, Tuesday, October 1, 2024, 12:30 p.m. – 1:30 p.m. (PST).
The program features two speakers from the CDTFA to give practitioners update on the new regulations impacting cannabis taxes and cannabis operators. The CDTFA will also speak about the current updates within the Sales and Cannabis Suppression unit including updates on inspections, audits, and collection.
We are pleased to announce that Robert Horwitz and Cory Stigile will be speaking at the upcoming Strafford Partnership Losses in Excess of Basis: Preparing for the IRS’ Latest Audit Campaign webinar, Friday, September 27, 2024, 10:00 a.m. – 11:50 a.m. (PST).
The IRS has an active partnership campaign to include audits of partners’ deductions of flow-through losses from partnerships. The Service believes that partners are deducting losses in excess of basis rather than suspending these losses when required. The IRS heightened its ability to track partners’ capital by implementing requirements to report negative tax basis capital in 2019, all partners’ capital accounts beginning in 2020, and added disclosures for Section 704(c) built-in gains and losses. The IRS is using data analytics to identify partnerships that are most likely noncompliant.
Practitioners working to meet these added reporting requirements must prepare to defend these positions and the calculations reported. Determining a partner’s outside basis, including whether tax basis capital has been appropriately captured and a partner’s share of liabilities, is complicated. Recent reporting rules have led to the discovery of allocation errors.
Pass-through entity advisers need to prepare for upcoming examinations and know how to handle audits of pass-through entities.
We are all looking forward to the ABA Tax Section 2024 National Institute on Criminal Tax Fraud and Tax Controversy Conference which will take place on December 12-14, 2024, at the Wynn Las Vegas. The tables are set and the topics ready to roll for what has become one of the most anticipated annual gatherings of criminal and civil tax practitioners and government tax officials.
We are fortunate to have the Commissioner of Internal Revenue, Danny Werfel in attendance to provide the Keynote at our annual Jerry Feffer Luncheon. We have an all-star lineup of high-level government speakers, Tax Court judges and criminal and civil tax practitioners who will be covering the following topics –
Low Income Taxpayers: How to Address Issues withIncompetent or Fraudulent Return Preparers
Criminal Tax Workshop
Nuts and Bolts of Tax Controversy Practice
Defending High Wealth Taxpayers in Civil andCriminal Tax Enforcement
Deference Denied: The New Landscape forRegulatory Enforcement
How Not To Be A Witness Against Your Client: Ethical and Other Considerations in Criminal Tax Investigations
Tools, Defenses, and Recent Developments in Collection
Voluntary Disclosure: Where Are We Now?
Federal Appellate Practice in Tax Cases
Criminal Enforcement in an Artificial Intelligence World –Proof Beyond a Reasonable Doubt
Welcome to the New Era of Tax Enforcement Relating to Partnerships and the Economic Substance Doctrine
Presenting and Cross-Examining the Expert Witness
Ensuring That Diverse Taxpayers Can NavigateThe Tax System
Common Ethical Conflicts in Tax Practice
The Employee Retention Credit How the Relief Program Became Civil and Criminal Enforcement Challenges
Conservation Easements: The Year in Review, and What To Expect
Registration, for what will likely be a sellout event again this year, can be found at the following link.
There are also a limited number of rooms available for a great price – but they will go fast, as it’s Vegas Baby! – so reserve now if you are interested. Here is the link.
If you are interested in sponsoring, please contact Michael Davis at michaeld@linksgroup.ca or by phone at (604) 341-9453 for more information.
On behalf of my Co-Chair Kathy Keneally and Sandra Brown and Frank Jackson who were instrumental in putting together the program, we look forward to seeing you in Vegas.
Steven Toscher Co-Chair 2024 Criminal Tax Fraud and Tax Controversy Conference Hochman Salkin Toscher Perez P.C. toscher@taxlitigator.com
We are pleased to announce that Jonathan Kalinski along with John Nail (Bradley Arant Boult Cummings LLP) will be speaking at an upcoming ABA Tax Section Virtual 2024 Fall Tax Meeting on The Latest “Need to Know” Legislative, Administrative & Litigation Updates, From Employee Retention Credits to Syndicated Conservation Easements, Tuesday, September 24, 2024, 2:30 p.m. – 4:00 p.m. (PST).
This panel will cover recent developments related to syndicated conservation easement litigation and recently announced IRS settlement initiatives, as discussed in IR2024-174. In addition, panelists will discuss the evolving landscape of employee retention credits, including recent IRS announcements related to processing and/or denying claims.
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TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 