HOCHMAN, SALKIN, RETTIG, TOSCHER & PEREZ, P.C., is internationally recognized as the preeminent tax law firm on the West Coast. The reputation of the firm for excellence and integrity in the tax community is unparalleled. The firm specializes in federal and state civil and criminal tax litigation, tax controversies and tax disputes with the federal, state, and local taxing authorities, white collar criminal defense, estate and business planning, probate, tax-exempt organizations, real estate, business and corporate transactions, and civil forfeitures. The firm's attorneys serve on prestigious committees of the state and local bar and accounting associations and many are regular contributors to leading journals and publications involving tax matters. The members of the firm recently co-authored the Tax Management Portfolio "Tax Crimes" (Pub. 636) (2d.) published by the Bureau of National Affairs. With respect to tax-related matters, few firms have the resources, expertise and collective experience offered by HOCHMAN, SALKIN, RETTIG, TOSCHER & PEREZ, P.C.
Several of the firm's attorneys gained their initial experience while working as Attorney-Advisors for the United States Tax Court in Washington, D.C., as tax prosecutors for the Office of the United States Attorney for the Central District of California, as trial attorneys for the Tax Division of the United States Department of Justice in Washington, D.C. or the Office of District Counsel of the Internal Revenue Service. Some have been appointed to serve on the IRS Advisory Council, the Advisory Board for the California Franchise Tax Board and the Advisory Council for the California State Board of Equalization.
The firm maintains an active national civil tax litigation and criminal tax defense practice and has received many notable decisions on behalf of its clients before the Federal Appellate Courts, the Federal District Courts, the Bankruptcy Courts, the United States Tax Court, various state courts, the California Franchise Tax Board, the California State Board of Equalization, and the California Unemployment Insurance Appeals Board. The firm enjoys a favorable reputation and is highly respected within the government as a result of its representation of individuals, corporations, partnerships, estates, and others in administrative tax controversies and tax disputes before the Internal Revenue Service, the Franchise Tax Board, the State Board of Equalization, and the Employment Development Department.
Firm representatives have participated in coordinating efforts of hundreds of other private tax practitioners in discussions and negotiations with the IRS resulting in the announcement of various IRS settlement initiatives bringing thousands of U.S. taxpayers into compliance and literally billions of dollars of revenue into the government. More recently, firm representatives have actively participated in numerous similar discussions regarding the IRS offshore voluntary disclosure programs (OVDP) as well as coordinating a venue for the dissemination of information to numerous taxpayer representatives and others. These ongoing efforts continue to provide significant benefits to U.S. taxpayers and their representatives throughout the world !
The firm's extensive tax expertise includes a strong emphasis in numerous areas of civil tax and criminal tax including:
The firm is internationally recognized as a leader in the representation of taxpayers throughout the world in matters involving the ongoing, extensive efforts of the U.S. government to identify undeclared interests in foreign financial accounts, voluntary disclosures (OVDP and otherwise), sensitive issue civil tax examinations, criminal tax investigations and prosecutions. The firm has represented literally hundreds of U.S. taxpayers participating in various IRS Offshore Voluntary Disclosure Programs (OVDP) and other forms of disclosure regarding foreign financial account values far exceeding billions of dollars, in the aggregate. The firm has also represented numerous taxpayers involved in Grand Jury investigations, criminal prosecutions and, when beneficial for the client, the effective negotiation of plea agreements involving the alleged misuse of foreign entities to conceal legal and beneficial interests in foreign financial accounts and assets. Few other firms have the similar firm-wide depth of knowledge and experience necessary to effectively represent the interests of their clients in these matters.