Hochman Salkin Toscher & Perez P.c

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(310) 281-3200Call Visit WebsiteVisit Website Map & DirectionsDirections9150 Wilshire Blvd Ste 300Beverly Hills, CA 90212 Write a ReviewWrite Review

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Mon - Fri:	9:00 am - 5:00 pm

Hochman Salkin Toscher & Perez P.c

Criminal Defense
Sandra Brown, in addition to having been the longtime Chief of the Central District of California’s Tax Division with hands-on trial experience as well as managerial oversight of all tax cases in the district, was First Assistant United States Attorney and Acting United States Attorney. In those roles, she had personal, supervisory involvement in federal criminal investigations and prosecutions of all manner of federal cases. Sandra was the final word on charging in high-profile criminal matters, and as a result became familiar with the nuts and bolts of the gamut of criminal cases charged in the Central District.

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Phone: (310) 273-1181

TollFree: (866) 770-7555

Neighborhoods

West Los Angeles, Beverly Hills

AKA

Hochman Salkin Rettig Toscher

Rettig, Charles

Hochman Salkin Rettig Toscher & Perez P.C.

Hochman Salkin Rettig Toscher & Perez

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http://www.taxlitigator.com

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Phone: (310) 281-3200

Address: 9150 Wilshire Blvd Ste 300, Beverly Hills, CA 90212

Website: http://www.taxlitigator.com

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Hochman Salkin Toscher & Perez P.c

Criminal Defense
Sandra Brown, in addition to having been the longtime Chief of the Central District of California’s Tax Division with hands-on trial experience as well as managerial oversight of all tax cases in the district, was First Assistant United States Attorney and Acting United States Attorney. In those roles, she had personal, supervisory involvement in federal criminal investigations and prosecutions of all manner of federal cases. Sandra was the final word on charging in high-profile criminal matters, and as a result became familiar with the nuts and bolts of the gamut of criminal cases charged in the Central District.
Fraud
We routinely represent and advise taxpayers involved in complex or sensitive issue civil tax examinations where substantial tax, civil penalty issues or possible assertions of fraudulent conduct may arise; voluntary disclosures of previously undisclosed interests in offshore financial accounts and assets through the ongoing IRS Offshore Voluntary Disclosure Program (OVDP), the IRS Streamlined Filing Compliance Procedures program or otherwise; voluntary disclosures involving purely domestic issues thereby both avoiding criminal prosecution and limiting civil penalty exposure; examinations involving “listed transactions” and other technical “tax shelter” transactions; examinations involving disputes over residency or source of income; taxpayers who have failed to timely file tax returns and in effectively defending criminal tax fraud administrative and Grand Jury investigations and prosecutions.
White Collar Crimes
In the Eye of the Beholder: What Moves a Tax Case from Civil to Criminal, ABA 37th National Institute on White Collar Crime, 2022
Theft
Drug Crimes
Grand jury investigations and criminal prosecutions for tax crimes and related white collar and drug crimes
Identity Theft
Co-author, “Will the Real John Doe Please Stand Up? Tax Identity Theft Developments,” Journal of Tax Practice and Procedure, February-March 2012
Money Laundering
Philipp Behrendt is licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets.

Business and Corporate Law

Corporate Law
“What the New IRA22 of 2022 Means for U.S. Tax Enforcement,” Tax Expert Guide 2022, November, 2022, “IRS Cracks Down on Tax Fraud by Creating a New Enforcement Office,” Los Angeles Lawyer, June, 2020, “The New Independent Office of Appeals Must Be Independent to Survive,” Journal of Tax Practice and Procedure, Summer, 2020, “Utilising the IRS Streamlined Compliance Programme to Manage US Tax Risk,” Financier Worldwide, March, 2020, “The New Taxpayer’s First Act, Among Other Benefits, Will Bring the IRS Into the Twenty-First Century,” December, 2019, Los Angeles Lawyer, “Is ‘Corporate America’ looking at increased tax enforcement?” Financier Worldwide, November, 2019, “The Impact of ‘Big Data’ on IRS Civil and Criminal Tax Enforcement,” Los Angeles Lawyer, August, 2019, Message from the Institute Chair, (UCLA Tax Controversy Institute), Journal of Tax Practice and Procedure, January, 2019; Cryptocurrency – FinCEN and Discovery of Hidden Wealth, Journal of Tax Practice and Procedure, September, 2018; Pitfalls of Being (or Representing a Cannabis Service Provider, U.S.C. Tax Institute Major Tax Planning, August, 2018; The Eighth Amendment Limits on FBAR Penalties – Common Sense Limitations Becomes a Legal Reality, Journal and Tax Practice Procedure, June-July, 2018; Cryptocurrency and IRS Enforcement – Get Ready for Uncle Sam to Look into your Digital Wallet, Journal of Tax Practice and Procedure, February-March, 2018; Targeting U.S. Luxury Real Estate – Forced Disclosure of Wealth, Thirty-Fifth International Symposium of Economic Crime, September, 2017; 30 Years After: What the Federal Sentencing Guidelines Have Meant for Criminal tax Enforcement, USC Tax Institute, August, 2017; When the Transaction Crosses the Border – Globalization and The Changing Face of Tax Enforcement, USC Tax Institute, August, 2017; Litigating the FBAR Penalty – Where Do We Go After IRS Appeals, Journal of Tax Practice & Procedure, June-July 2017; Proposed 2017 Amendments to Sentencing Guidelines May Be Good News for Tax Offenders, Journal of Tax Practice & Procedure, December 2016-January 2017; Looking for hidden wealth: in search of beneficial owners,” Financier Worldwide, October 2016; “The Continuing Evolution of FBAR Enforcement,” Journal of Tax Practice & Procedure, April-May 2016; “2015 Tax Law Review,” Los Angeles Lawyer, April 2016; Mr. Toscher is the author or co-author of numerous articles. A representative sample include “The Tax Man Cometh – IRS Expansion of Section 482 Transfer Pricing Enforcement to Middle-Market Companies,” Corporate Disputes Magazine, Jan-Mar 2016; “A Message from the Institute Chair—UCLA Extension, 32nd Annual Tax Controversy Institute,” Journal of Tax Practice & Procedure, December 2015-January 2016; “New Partnership Examination Procedures Designed to Simplify Will Cause Complications and Additional IRS Scrutiny of Large Partnerships,” Journal of Tax Practice
Business Disputes
Recognizing a lifetime of achievements and contributions to the field of taxation, in 2003 the Taxation Section of the Los Angeles County Bar Association bestowed its highest honor on Avram Salkin, the Dana Latham Award. In 2007 Mr. Salkin was the recipient of the Joanne M. Garvey Award given by the Taxation Section of the State Bar of California for lifetime excellence in the practice of tax law. Mr. Salkin was a Member of the Board of Governor’s for the Beverly Hills Bar Association and was the Vice-Chair for the Tax Advisory Commission for the California State Bar Board of Legal Specialization. He is a Past-Chair of both the Business Law Section and the Taxation Section of the Beverly Hills Bar Association and has served on the Executive Committee of the Taxation Section of the Los Angeles County Bar Association. Previously, he served as the Tax Articles Editor of the Los Angeles Lawyer and the Los Angeles County Bar Journal.
Business Transactions
Limited Liability Companies
Cory Stigile specializes in tax controversies as well as business and international tax. His representation includes federal and state tax controversy matters, including sensitive tax-related examinations and investigations for individuals, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). He has litigated cases in the U.S. Tax Court, the U.S. District Court, the Court of Federal Claims and the 9th Circuit Court of Appeals.
Trade Secrets
Intellectual Property

Sexual Harassment
The New Section 162(q) of the 2017Tax Cuts & Jobs Act: The Price of Confidentiality in Sexual Harassment Cases, #NoDeduction by Sandra R. Brown

Eminent Domain
Actions affecting property in which the United States claims a tax lien (including actions in interpleader, eminent domain and for partition), probate proceedings
Easement

Immigration Law

Citizenship and Naturalization

Trusts and Estates

Estate Planning
Prior to joining the firm, Mr. Greenwade gained tax and criminal litigation experience as a law clerk with Carico Macdonald Kil& Benz LLP, a probate litigation and trust and estate planning firm, and as a law clerk with the Los Angeles County District Attorney’s Office, where he assisted and strategized with lead prosecutors in high-profile cases in the Major Crimes Division.
Wills
Trusts
Our estate planning lawyers have extensive experience in combining tax and estate-planning strategies and techniques to assist our clients with their estate planning, business succession planning, and trust administration needs. Our practice includes a special emphasis on estate planning for business owners focusing on the potential future transfer or sale of the business operations on the owner’s death or retirement.
Probate
Avram Salkin is a founding member of the firm. He has over fifty years of extensive experience in resolving complex Federal and state tax controversies and disputes, in structuring and negotiating complex transactional matters (including the acquisition and disposition of real estate and businesses), family wealth planning, estate planning and probate. Avram Salkin is a Certified Specialist in both Taxation and Estate Planning, Trust and Probate Law, by the The State Bar of California Board of Legal Specialization.

Bankruptcy
Foreclosure
Tax Law
Our tax practice promotes appropriate and legitimate tax planning strategies to solve complicated tax and business matters for individuals and closely-held entities, including the organization, maintenance, reorganization and dissolution of business entities, in addition to structuring and negotiating complex real estate, business, and acquisitions and dispositions.

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