We are pleased to announce that Michel Stein along with Phillip Colasanto, Caroline Ciraolo, and Daniel Price will be speaking at the upcoming NYU 14th Annual Tax Controversy Forum on “Coming in From the Cold: The Future of Voluntary Disclosures” on Friday, June 24, 2022, 2:45 p.m. – 3:45 p.m. (EST).

For more than 70 years, the IRS has maintained a voluntary disclosure policy designed to encourage taxpayers to come in from the cold and self-report noncompliance. In 2018, the voluntary disclosure program was updated to provide new procedures. In its most recent annual report, the Taxpayer Advocate Service noted that the new procedures are substantially more onerous and uncertain than the old procedures, and may actually discourage taxpayers from stepping forward to self-disclose. This panel will discuss the latest voluntary disclosure developments, including the application of the updated program to cryptocurrency, and provide suggestions on how practitioners should advise their clients to make the best use of the new voluntary disclosure procedures. 

Click Here for more information.

We are pleased to announce that Sandra Brown will be speaking at the upcoming NACDL’s 2022 West Coast White Collar Conference seminar, “Only Two Things Are Certain and This Isn’t About Death: Defending Criminal Tax Cases” on Friday, June 17, 2022, 10:30 a.m. (PST) at the Kona Kai Resort & Spa, San Diego.

The panel will provide an introduction to criminal tax laws and procedures as well as discuss the various crimes “arising under” the tax laws, the unique regulations governing the investigation and prosecution of these crimes, and the federal agencies and components involved. Learn from a group of former distinguished, government tax prosecutors how criminal tax cases tend to originate, their typical life cycles, and the opportunities for advocacy by defense counsel along the way, the types of evidence the government tends to assemble, common defenses, and potential collateral consequences involved in such cases.

Click Here for more information.

We are pleased to announce that Robert Horwitz, Cory Stigile and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Partnership Losses in Excess of Basis: Preparing for the IRS’ New Audit Campaign” on Wednesday, June 15, 2022, 10:00 a.m. – 11:50 a.m. (PST).

This webinar will prepare pass-through advisors to withstand IRS challenges to partners’ basis calculations. Our panel of federal tax experts will guide partners and tax professionals through the calculations necessary to determine a partner’s basis in a partnership, the IRS examination, and handling prior period capital account errors.

In February 2022, the IRS announced its latest partnership campaign would 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. Although new, this action is not unanticipated. The IRS has 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 who have been scrambling to meet these added reporting requirements now must prepare to defend these positions and calculations reported. Determining a partner’s outside basis, including whether tax basis capital has been appropriately captured and a partners’ 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.

Listen as our panel of IRS examination experts explains how to properly maintain and support partners’ basis in partnerships and how to defend these calculations when representing partners.

We are also pleased to announce that we will be able to offer a limited number of complimentary and reduced cost tickets for this program on a first come first serve basis. If you are interested in attending, please contact Sharon Tanaka at sht@taxlitigator.com. 

Click Here for more information.

We are pleased to announce that Edward Robbins, Jr., Sandra Brown and Michel Stein will be speaking at the upcoming Lorman webinar, “Currency Transaction Report: How to File and Common Errors” on Tuesday, June 14, 2022, 10:00 a.m. – 11:05 a.m. (PST).

This course will educate and assist United States persons who have the obligation to file any of the numerous currency transaction reports and the professionals who prepare and file these forms on behalf of their clients. The information contained in these forms assists law enforcement in its anti-money laundering efforts. When businesses and individuals comply with the reporting laws, they provide authorities with an audit trail to stop tax evasion, drug dealing, terrorist financing, and other criminal activities. The government is very serious about these currency transaction reports and has put in place serious civil and criminal penalties for noncompliance. This information is critical for persons involved in the preparation of these currency transaction reports so that they can be confident that their efforts comply with the law and that they and their employers will avoid sanctions for noncompliance.

Click Here for more information.

We are pleased to announce that Steven Toscher, Michel Stein and Robert Horwitz will be speaking at the upcoming CalCPA webinar, “Understanding Opportunity Zones Tax Incentives under TCJA 2017 in the Face of New Congressional Oversight and the TIGTA Report” on Tuesday, June 7, 2022, 9:00 a.m. – 10:00 a.m. (PST).

Congress is considering changes to Qualified Opportunity Zones (QOZs); this program will examine the tax and operational issues to consider when advising your clients whether to invest in QOZs and how pending legislation may affect QOZs in the future

Learning Objectives

  • To inform participants about the tax and operational basics of QOZs so they can advise and assist clients in determining whether to invest in a QOZ 
  • How to defer gain
  • What can lead to the inclusion of gain and pending changes to QOZ provisions 

Major Subjects

  • What is a QOZ and how one is created
  • What is a Qualified Opportunity Fund (QOF) and how to invest in a QOF
  • Types of gain eligible for deferral, election of deferral and what triggers the inclusion of deferred gain
  • How proposed legislation could impact QOZs and QOFs

Click Here for more information.

We are pleased to announce that Steven Toscher and Michel Stein will be speaking at the upcoming CSTC San Francisco Bay Chapter webinar, “Cryptocurrency Tax Compliance: Tax Filing Requirements; Managing IRS Examinations” Wednesday, June 1, 2022, 6:00 p.m. – 8:00 p.m. (PST).

This course will provide tax counsel, accountants, and other advisers with a critical first look at recent IRS enforcement actions on taxpayer compliance and reporting obligations for cryptocurrency transactions. The panel will discuss the IRS position on the tax treatment of cryptocurrency, analyze IRS monitoring to increase compliance, consider criminal investigations and prosecutions for failing to report crypto transactions accurately. The panel will define proper reporting and tax treatment for “mining” and exchanging cryptocurrency along with tactics in managing IRS examinations and audits.

Click Here for more information.

We are pleased to announce that Dennis Perez, Sandra Brown, and Cory Stigile will be speaking at the upcoming Strafford webinar, “Navigating IRS Scrutiny of R&D Tax Credits: Qualified Research Activity, Expenses, Research Credit Claims Audits” on Wednesday, June 1, 2022, 10:00 a.m. – 11:30 a.m. (PST).

This CLE/CPE webinar will guide tax professionals and advisers on navigating IRS scrutiny and challenges to the R&D tax credit for small and large businesses and international taxpayers. The panel will discuss the recent IRS crackdown on documentation of research credit claims, managing IRS audits, qualified research activities (QRAs) and qualified research expenses (QREs), safe harbor for certain taxpayers, and techniques to assist in documenting and claiming R&D credits.

For many businesses, the R&D tax credit is one of its most significant tax benefits. When claiming the R&D credit, determining what constitutes a QRA and calculating QREs can be challenging.

The IRS has strict standards in examining R&D tax credit claims and has announced changes in documentation requirements for claims made concerning the credit for increasing research activities. In addition, the IRS recently issued procedural guidance now requiring taxpayers to submit specific pieces of information with any amended returns or administrative adjustment requests that claim an R&D credit.

Generally, Sec. 41 allows a credit for a percentage of a QRE that a taxpayer incurs engaging in research activities. The Code provides a four-part test to determine whether an activity can be considered a QRA. Expenditures, including wage expenses with sufficient nexus to the QRA, can be included in calculating the expenditure base. However, substantiating that an activity qualifies as a QRA can be complex, and tax professionals must know the standards and limits in utilizing this important and often overlooked credit.

Listen as our experienced panel discusses the recent IRS crackdown on documentation of research credit claims, managing IRS audits, QRAs and QREs, and techniques to assist in documenting and claiming R&D credits.

We are also pleased to announce that we will be able to offer a limited number of complimentary and reduced cost tickets for this program on a first come first serve basis. If you are interested in attending, please contact Sharon Tanaka at sht@taxlitigator.com. 

Click Here for more information.

Posted by: evanjdavis | May 20, 2022

EVAN DAVIS Quoted in Tax Notes on Cryptocurrency

Tax Lawyers Find New Obstacles Defending Client Crypto Positions

The same things that some cryptocurrency buyers like about the instrument could pose trouble
when it comes to trying to defend taxpayers in audits or court proceedings.

Click Here to read full article.

Cryptocurrency Holds More Curveballs for Tax Trials

Blockchain technology presents an evolving area of trial practice law for Justice Department Tax
Division lawyers preparing to present their cases.

Click Here for full article.

We are very pleased to announce that Sandra Brown, Evan Davis and Steven Toscher are featured in this month’s Los Angeles Lawyer discussing the research and development credit as applied in the entertainment industry. And you can get MCLE. 

Many businesses perform some type of research and development (R&D)—the lifeblood of a growing and prosperous economy. A primary example is the entertainment industry in which many companies over the years have partly become technology companies. A telltale sign of such growth in R&D is the number of companies taking advantage of these federal tax credits under Internal Revenue Code Section 41. This can be seen, for example, in the public Securities and Exchange Commission filings of major entertainment companies. However, many smaller businesses may not realize that some of their activities also may qualify for R&D tax credits.  Whether a business is large or small, the ability to claim, and withstand the IRS’s scrutiny of, R&D tax credits is something worth learning about.

Click Here for full article.

We are pleased to announce that Steven Toscher will be speaking at the upcoming NYU 14th Annual Tax Controversy Forum on “The Future of Voluntary Disclosures” on Friday, June 24, 2022, 2:30 p.m. – 3:30 p.m. (EST).

The annual NYU School of Professional Studies Tax Controversy Forum features interactive presentations delivered by expert practitioners who cover a broad range of issues regarding tax audits and tax litigation at all levels.

Content encompasses the timeline of controversy work—from planning for the examination of a return and audit and administrative appeals processes, to litigation techniques and strategies. Panelists representing both taxpayers and the government share views on the latest issues and perspectives on tax controversies. Attendees learn practical solutions and valuable insights from leading authorities from across the profession.

This year’s NYU Tax Controversy Forum will feature updates on what the IRS is doing to enhance compliance through communication and enforcement. Panels will highlight the new IRS focus on intra-agency collaboration, new initiatives with respect to penalties and fraud referrals, and IRS’ handling of tax collection challenges.  

Click Here for more information.

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