The Internal Revenue Service (IRS) launched a “soft letter” campaign advising taxpayers believed to have engaged in cryptocurrency transactions of their obligations to report those transactions and the ability to file amended tax returns to correct prior reporting and compliance issues.
The program will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and reporting income and gain on cryptocurrency (e.g., Bitcoin) transactions. We will also discuss the IRS' position on cryptocurrency as property rather than cash, analyze IRS monitoring to increase compliance and define proper reporting and tax treatment for hard forks, "mining" and exchanging cryptocurrency. Further, we will address recently released IRS Revenue Ruling 2019-24 and the updated FAQs regarding the taxation of cryptocurrency, with a particular focus on the recent IRS enforcement initiatives to identify and tax virtual currency activity and how this soft letter campaign fits into the IRS voluntary disclosure practice.
Steven Toscher is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. He maintains an active practice before the United States Tax Court, the Federal District Courts in California and Nevada, the Ninth Circuit Court of Appeals and the California State Courts. He frequently appears before the Internal Revenue Service, the California Franchise Tax Board and the California State Board of Equalization.
MICHEL R. STEIN is a principal at Hochman, Salkin, Rettig, Toscher & Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For almost 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.
Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise.
Throughout his career, Mr. Stein has represented thousands of individual, business and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayers and their advisors around the world.
Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.
Prior to joining the firm as a principal, Sandra Brown spent more than 26 years as a federal trial lawyer, including serving as the Acting United States Attorney and twice as the First Assistant United States Attorney, in the Office of the U.S. Attorney, Central District of California. In addition to leading the Central District of California’s United States Attorney’s Office, where she supervised approximately 270 attorneys in the largest Justice Department Office outside of Washington, D.C., Ms. Brown also served as the Chief of the Tax Division for more than ten years where she supervised lawyers within the United States Attorney’s Office, the Department of Justice Tax Division and the Department of Treasury who were responsible for complex Federal civil and criminal tax matters, including related grand jury proceedings, trials, and appeals.
Ms. Brown’s broad range of experience in complex civil tax controversies and criminal tax investigations and litigation includes having personally handled over 2,000 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. She obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax counsel as well as a member of the California State Bar, American Bar Association Tax Section & Criminal Justice Section, NYU Tax Controversy Institute Advisory Committee, Beverly Hills Bar Association Taxation Section, Federal Bar Association, California Lawyers Association Tax Section, and the Women’s White Collar Defense Association.
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.
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