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.
Hochman Salkin Toscher Perez P.C. is pleased to announce Sebastian Voth has joined our firm as a Principal.
Sebastian joins us as a former Special Trial Attorney (STA) with the IRS Office of Chief Counsel’s Strategic Litigation Division with over fifteen years of government experience. As an STA he led trial teams in all phases of litigation before the United States Tax Court. Sebastian has been recognized as the IRS Nationwide Attorney and Special Trial Attorney of the Year by SB/SE and U.S. Department of Treasury Outstanding Litigator. His experience both in Court and in working on complex tax matters makes him uniquely suited to join our seasoned bench of tax litigators with experience from the Department of Justice, IRS Chief Counsel, and the United States Tax Court.
Steven Toscher, Managing Principal Hochman Salkin Toscher Perez P.C. toscher@taxlitigator.com
We are just about 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!
This year’s Institute will feature keynotes from Commissioner of Internal Revenue Danny Werfel, Chief Judge of the Tax Court Kathleen Kerriganand IRS Criminal Investigation Deputy Chief Shea Jones. We are also pleased to announce that the annual Bruce I. Hochman Award will be presented to our Taxpayer Advocate Erin Collins.
Last, but certainly not least, our traditional evening networking reception and cocktail party will include a special celebration in recognition of 40 years of the Institute. A complete list of all the programs can be found on the registration link below. Please join us.
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.
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.
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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TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 