TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

Dear Colleagues-

We are now less than two months away from celebrating the 40th Anniversary of the UCLA Extension Tax Controversy Institute. Following the decades’ long tradition of presenting stellar topics and presenters which have made this the “can’t miss tax controversy program,” this year is sure to be one of our best ever featuring keynotes from Commissioner of Internal Revenue Danny Werfel, Chief Judge of the Tax Court Kathleen Kerrigan and IRS Criminal Investigation Deputy Chief Shea Jones. 

The Bruce I. Hochman Award will be presented to our Taxpayer Advocate Erin Collins. This year, our traditional evening reception and cocktail party will include a special celebration of 40 years of the Institute. A complete list of all the programs can be found on the registration link below. Please join us.

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Steven Toscher and Sandra R. Brown, Co-Chairs
2024 UCLA Extension Tax Controversy Institute
Hochman Salkin Toscher Perez P.C.
toscher@taxlitigator.com

We are pleased to announce that Evan J. Davis will be speaking on Financial Intelligence and the Strategy of Disruption – The Benefits and Risks at the upcoming 41st International Symposium on Economic Crime at Jesus College University of Cambridge, Saturday, September 7, 2024, 8:00 a.m. (BST).

The Cambridge International Symposium on Economic Crime is unique. It is organized by some of the world’s leading educational and research institutions with the involvement of numerous governmental agencies, the judiciary, the professions, compliance bodies, and the business world. It provides a forum for the practical analysis and discussion of the real threats facing our world as a result of criminal and subversive activity. The Symposium is run on a non-profit making basis – its primary objective being to promote meaningful co-operation in the prevention and control of economically motivated crime and misconduct.

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

We are pleased to announce that Cory Stigile and Philipp Behrendt have published a comprehensive article in The Tax Advisor, titled “Sec. 6603 Deposits Under the BBA Audit Regime.” This insightful piece, featured in the July 2024 issue, addresses the critical issue of making deposits under IRC Section 6603 within the context of BBA Partnership audits.

Understanding how to manage interest accrual on disputed tax amounts is essential, especially with IRS noncorporate interest rates rising significantly. Stigile and Behrendt explore how making deposits can suspend interest accrual and offer temporary relief during tax controversies. Their article delves into the procedural aspects and potential pitfalls associated with this strategy, providing essential guidance for tax representatives navigating the complexities of the BBA audit regime.

Don’t miss this valuable resource for managing tax disputes effectively!

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For more information, please contact Cory Stigile at stigile@taxlitigator.com

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

We are pleased to announce that Michel R. Stein along with Eric Cirelli (Director of Field Operations, Global High Wealth and High Income Compliance Strategy Internal Revenue Service), Justin D. Scheid (Deputy Area Counsel, IRS Office of Chief Counsel, LB&I) and Aaron Vaughan (Managing Director, KPMG LLP), will be speaking on Handling High Wealth Taxpayer Examinations – What We Can Expect Now at the upcoming Beverly Hills Bar Association webinar on Tuesday, September 3, 2024, 12:30 p.m. – 1:30 p.m. (PST).

In connection with the additional appropriations from the Inflation Reduction Act, the IRS has committed to shift more attention to high-income earners – a group it defines as taxpayers earning at least $400,000 per year. This panel will inform attorneys about the IRS’s announced enforcement priorities for high-income earners and large partnerships, the expected timeline for additional enforcement, and strategies for representing clients in IRS examinations of high-income taxpayers.

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

We are pleased to announce that Philipp Behrendt along with Marina Muchakova and Ege Tekiner will be speaking at the upcoming Crypto Tax Forum on Audits and Litigation webinar, Thursday, September 5, 2024, 1:45 p.m. – 2:45 p.m. (CEST).

Exchange Ideas in the Metaverse, with the Best Tax Professionals in the Industry. Gain exclusive access to industry leaders and national tax authorities. Learn about best and worst practices in crypto assets taxation internationally. Expand your network and gain the insights you need to make well-informed decisions.

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

We are pleased to announce that Michel R. Stein along with Maria Dolan (Deputy Director Pass-Through Entities, LB&I, IRS), Richard Tierney (Director of Exam, SB/SE, IRS) and Jonathan Strouse (Partner, Harrison LLP, Chicago, IL) will be speaking on IRS Examinations for High Wealth Individuals and Their Partnerships – What to Expect in Tax Enforcement After the Inflation Reduction Act Funding at the upcoming St. Louis Summer Tax Summit being held at the Missouri Athletic Club on Tuesday, August 27, 2024, 1:30 p.m. – 2:30 p.m. (CT).

In connection with the additional appropriations in the Inflation Reduction Act, the IRS has committed to shift more resources to high-income earners and large partnerships. This panel will explain the IRS’s announced enforcement priorities for high-income earners and large partnerships, the expected timeline for additional enforcement, and strategies for representing clients in IRS examinations of high-income taxpayers.

• Learn about the Global High Wealth Group audit program
• Better Understand the Enforcement Priorities of LBI and SB/SE 
• Decipher the BBA partnership examination process
• Learn about the IRM procedures application to case selection and examination  

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

Curious about the latest developments in crypto taxation?

We are pleased to announce that Michel R. Stein and Philipp Behrendt have co-authored an article, published in the Summer 2024 issue of the Journal of Tax Practice & Procedure, titled “Decoding Crypto Taxation: Essential Updates for Professionals.” This article provides a comprehensive update on IRS enforcement in the realm of digital assets and an overview of the key crypto transactions you need to know for 2023/2024. Dive in to stay ahead in the ever-evolving world of crypto tax enforcement!

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

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

Want to know what keeps many tax controversy practitioners up at night? Representing taxpayers faced with parallel tax investigations certainly makes the list! 

We are pleased to announce that Sandra R. Brown and Hunter Keaster wrote an article published in the Summer, 2024 issue of the the Journal of Tax Practice & Procedure, titled “Criminal, Civil, or Both: Navigating Parallel Investigations with the IRS” which details the complexity of parallel tax investigations and provides tips for tax practitioners to better wield the appropriate shield or sword in defending the rights of clients in such cases.

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

For more information, please contact Hunter Keaster at hk@taxlitigator.com

We are pleased to announce that Michel R. Stein, Evan Davis and Philipp Behrendt will be speaking at the upcoming CalCPA Cryptocurrency Compliance webinar, Tuesday, August 13, 2024, 9:00 a.m. – 10:30 a.m. (PST).

The program will provide tax advisers and compliance professionals with a practical look at IRS guidance for calculating and reporting income and gain on cryptocurrency (e.g., Bitcoin) transactions. We’ll discuss the IRS’s latest positions on cryptocurrency, analyze IRS efforts to increase compliance and define proper reporting and the tax treatment for convertible virtual currency and cryptocurrency, stablecoins, as well as NFTs. We will address recently released Broker Reporting Regulations, the latest released IRS Guidance, the recent IRS enforcement initiatives to identify digital asset activity, how the IRS enforcement strategy fits into the voluntary disclosure practice, and the risks of criminal prosecution related to unreported and improperly reported cryptocurrency transactions. 

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

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

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

We are pleased to announce that Jonathan Kalinski along with Ani Galyan (Galyan Law) will be speaking at an upcoming Strafford webinar on Tax Implications of Reclassifying Cannabis From a Schedule I to a Schedule III Drug, Tuesday, July 30, 2024, 10:00 a.m. – 11:30 a.m. (PST).

This webinar will provide tax professionals guidance on key tax implications of rescheduling cannabis from a Schedule I to a Schedule III drug. They will discuss the recent move by the Department of Justice to reclassify cannabis as a less harmful Schedule III drug under the Controlled Substances Act, its impact on federal and state-level taxation, Section 280E, and tax planning methods and reporting requirements for cannabis businesses under current tax law.

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