The Inflation Reduction Act has supplemented the IRS budget by $90 billion, and enforcement efforts are expected to ramp up. This legal tax guide parses truth from rumor and offers clear guidance we have so far on the current IRS priorities and on the way businesses, trusts, and estates can shore up compliance and become better prepared for more likely audits. Stay ahead of the curve - register today!
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Sandra R. Brown is an attorney with the law firm Hochman Salkin Toscher Perez P.C. in Beverly Hills, California. Ms. Brown joined the firm as a principal after serving most recently as the first Assistant United States Attorney for the Central District of California. Her 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. From March 2017 to January 2018, Ms. Brown served as the acting United States Attorney. 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., she 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 earned her LL.M. degree in taxation from the University of Denver and her J.D. degree from Thomas M Cooley Law School. She is a fellow, American College of Tax Counsel, as well as a member of the American Bar Association, the NYU Institute on Federal Taxation, the NYU Tax Controversy Institute, the Beverly Hills Bar Association, the Federal Bar Association, the State Bar of California and the Women White Collar Defense Association.
Michel R. Stein is an attorney with the law firm Hochman Salkin Toscher Perez P.C. in Beverly Hills, California. Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 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. He 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. Mr. Brown has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise. He earned his B.S. degree from California State University, Northridge, his J.D. degree from the University of California, Hastings College of the Law and his LL.M. in taxation from NYU School of Law. Mr. Stein is a member of the State Bar of California, the Los Angeles County Bar Association, the American Bar Association, the California State Bar Association, the Beverly Hills Bar Association, the Association of Tax Counsel, Los Angeles and is a fellow of the American College of Tax Counsel.
Steven Toscher is an attorney with the law firm Hochman Salkin Toscher Perez P.C. in Beverly Hills, California. Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney (C.D. Cal.), numerous state taxing authorities and in federal and state court litigation and appeals. He enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, excise taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues. Mr. Toscher earned his undergraduate degree in accounting from the University of Nevada, Las Vegas and his Juris Doctor degree from the University of San Diego. In addition to his law practice, he has served as an adjunct professor at the University of Southern California since 1995, where he teaches federal tax procedure. He is a fellow of the American College of Tax Counsel and is a member of the California, Nevada and Colorado bars. Mr. Toscher is a member of the Tax Sections of the American Bar Association, the California Bar, the Los Angeles County Bar Association and Beverly Hills Bar Association.
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