TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Philipp Behrendt will be speaking at the upcoming California Lawyers Association webinar “The Use of AI for Tax Litigation,” Tuesday, August 8, 2023, 12:00 p.m. – 1:00 p.m. (PST).

The webinar will delve into the transformative impact of artificial intelligence on tax litigation practices. Attendees can look forward to gaining valuable knowledge on the use and still existing limitations of AI tools and techniques that can be employed by tax professionals. The speakers will also address the ethical considerations surrounding the use of AI in this context, ensuring a holistic understanding of the topic. The program will assist attendees to uncover the strategies for effective prompt engineering, leveraging AI for optimal results.

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Our partners, Dennis Perez and Sandra Brown, had the privilege of speaking in San Diego on Friday at the 8th Annual USD School of Law- RJS LAW Tax Controversy Institute. 

Joining Dennis Perez on the Government Loans Panel, which provided an in depth focused on PPP, EIDL and ERC audit and fraud issues, were AUSA Dylan M. Aste, Special Litigation Counsel Joseph Orabona, and IRS CI SSA Jason Powell as well as moderators Kaveh and Sam Imandoust. 

Sandra Brown was joined on the Criminal Tax Investigations and Prosecution panel by the Honorable Allison H. Goddard, former AUSA Daniel Silva, and former IRS CI Chiefs Don Fort and Victor Song. Always nice to present with former colleagues and a bonus to learn various tips about federal court procedures and sentencings from Magistrate Judge Goddard.

Many thanks to Ronson J. Shamoun for co-hosting such an informative conference event, and to our tremendous panelists for their enlightening comments on these interesting tax controversy topics.

We are pleased to announce that Steven Toscher, Michel Stein, and Philipp Behrendt will be speaking at the upcoming CalCPA webinar “Cryptocurrency Compliance 2023,” Tuesday, August 8, 2023, 9:00 a.m. – 10:00 a.m. (PST).

Keep abreast of the IRS’s continuous efforts to enhance compliance in the crypto space. Join us for a practical look at the IRS enforcement strategy, established reporting principles as well as recent guidance on digital assets taxation. The Program is your guide to navigating the intricacies of digital asset taxation. Gain valuable insights what the IRS positions on many hot topic items in the world of digital asset taxation actually is, allowing you to provide expert guidance to your clients. Being up to date ensures you can offer the most current and relevant solutions to your clients. We also address how to ensure FBAR compliance and explore voluntary disclosure practices to protect your clients’ interests.

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Please join us July 28, 2023 for the CalCPA 2023 Annual Income Tax Seminar.

We have an excellent line up of programs –

How to Help an Individuals with Unreported or Misreported Crypto Transactions
(8:05 a.m. – 9:25 a.m. PST)
Featuring Evan Davis

R&D Credit Hot Topic and California Considerations
(1:05 p.m. – 2:20 p.m. PST)
Featuring Cory Stigile

The Annual Income Tax Seminar is a collaboration of CalCPA and the California Lawyers Association Taxation Section that will provide comprehensive insights into critical topics shaping the world of taxation. This event is tailored for tax professionals, CPAs, attorneys, and financial advisors seeking to stay at the forefront of the industry.

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The Employee Retention Credit (ERC) has been a lifeline for businesses struggling during the COVID-19 pandemic. Designed to provide financial assistance to eligible employers who kept their workforce employed during times of economic hardship, the ERC has proven to be a vital source of support for many. However, with its increasing popularity, aggressive marketing tactics, and potential for misuse, the IRS has found itself facing a growing challenge in ensuring the program’s integrity.

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Jonathan Kalinski quoted in Tax Notes article on newly filed Tax Court cases challenging the IRS’ position in applying IRC Section 280E to Offers in Compromise for marijuana businesses. Offers in Compromise are challenging for marijuana businesses because the IRS uses 280E disallowed expenses in determining collection potential, creating a phantom cash problem. 

“The fiction of ignoring taxpayer expenses for considering an OIC makes no one’s life easier as the IRS struggles to collect phantom cash and the taxpayer struggles to pay it.”  

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We are pleased to announce that Steven Toscher, Michel Stein, and Sandra Brown will be speaking at the upcoming CPA Academy webinar “Tax Controversy Hot Topics,” Tuesday, July 25, 2023, 8:00 a.m. – 9:00 a.m. (PST).

This webinar will cover critical practice and procedural issues facing practitioners, including IRS priorities, the new emphasis on fraud investigations, and referrals to the criminal investigation division.

Practitioners at all levels need to have the most up-to-date information to best advise their clients, and this webinar will cover a broad range of topics that any practitioner will benefit from knowing. The presenter will cover updates on IRS Enforcement and what the IRS plans to do with its additional funding, issues around high-wealth examinations and high-income non-filers, John Doe summons, Digital Assets/Cryptocurrency enforcement, and options for taxpayers with undisclosed foreign assets as well as the latest on the Maltese pension plans and on Employee Retention Credits.

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Please join us July 28, 2023 for the USD School of Law – RJS Law Tax Controversy Institute at the San Diego Knauss Center for Business Education, Nexus Theater University of San Diego.

We have an excellent line up of programs –

A Guide to IRS Criminal Tax Investigations and Prosecutions

Featuring Sandra Brown

IRS Cares about CARES Act Relief Abuses: PPP, EIDL and other Government Covid Relief Audits and Criminal Investigations

Featuring Dennis Perez

The Institute is the premier tax controversy event in San Diego. The region’s top tax attorneys, CPAs, and law/business school professors will discuss topics including government loan relief and abuses, challenges in cross-border transactions, and practical and realistic solutions in Trust, Estate Planning, and Tax matters. 

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For more than 85 years the Tax Court, its predecessor, the Board of Tax Appeals, and those courts of appeal that addressed the issue, held that the statute of limitations for filing a petition for redetermination was jurisdictional. When a prerequisite for a lawsuit is jurisdictional, it means that if the prerequisite has not been met, the court has no power to hear the case. It was required to dismiss the case for lack of jurisdiction. 

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Puerto Rico has been offering tax incentives to wealthy individuals, hedge fund managers, and cryptocurrency traders since 2012. These tax incentives have allowed them to legally avoid paying federal income tax and certain other taxes. However, recent developments have brought these tax breaks under scrutiny, with US prosecutors and IRS agents launching criminal and civil investigations into their potential abuse. In this blog post, we will explore the controversies surrounding Puerto Rico’s tax incentives and the increasing scrutiny faced by those who have taken advantage of them.

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