Steven Toscher

USA: California

Hochman, Salkin, Rettig, Toscher & Perez, P.C.
9150 Wilshire Blvd., Suite 300
Beverly Hills, California 90212
United States

Tel: (310) 281-3200
Fax: (310) 859-1430

Email: toscher@taxlitigator.com
Web: www.taxlitigator.com

Steve 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.

Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and Grand Jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury).

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.

Representative Experience

Steve Toscher widely respected 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 and assets and the coordination of effective and efficient voluntary disclosures (OVDP, Streamlined Procedures and otherwise).

Recently, Steve Toscher received a judgment of acquittal in a matter involving allegations of a conspiracy between the client, the client’s independent certified public accountant and others relating to the clients personal taxes as well as those of the clients son and his business enterprise, including the use of a foreign bank account and a foreign trust. Others included in the indictment previously pled guilty and the former accountant testified at trial as a cooperating witness for the Government. This is believed to be among the first unsuccessful prosecutions relating to the use of matter involving use of foreign trusts and foreign financial accounts in the Government’s ongoing, extensive international enforcement efforts.

Professional Experience

Before entering private practice, Steve Toscher served as a trial attorney for the Tax Division of the United States Department of Justice in Washington, D.C. and, before that, as a Revenue Agent with the Internal Revenue Service. 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.

Throughout his career, Mr. Toscher has been actively involved in California unitary tax controversies and Federal and State employment tax controversies involving garment workers; health care workers; insurance salesmen; financial services representatives; real estate personnel and production employees. He has also been lead trial counsel in tax related matters involving government securities; wind and solar energy; horse racing and breeding; equipment leasing; motion picture transactions; oil and gas and other natural resource ventures. He also served as Special Tax Litigation Counsel for the Securities and Exchange Commission court appointed receiver in Securities and Exchange Commission v. Elmas Trading Corp., et al., Case No. CV-R-85-263-ECR (D. Nev).

Hochman, Salkin, Rettig, Toscher & Perez P.C. is internationally recognized for excellence, integrity and the ability to achieve the best possible results for our clients throughout the world. Our experienced tax lawyers have outstanding tax-related credentials and are routinely recognized as leaders in handling all aspects of sophisticated tax controversies and criminal tax matters.

The firm specializes in expediting favorable resolution strategies for administrative tax controversies and tax disputes with the federal, state and local taxing authorities, federal and state civil tax litigation, defense of criminal tax investigations and prosecutions, white collar criminal defense, and family wealth transfers and related planning opportunities. We routinely handle representations involving complex and sensitive issue tax examinations and administrative appeals, voluntary and “scorched earth” tax collection problems, responding to summonses and subpoenas, and trials and appeals before all Federal courts. We enjoy an extensive history of successfully resolving the most sensitive, complex tax matters for our clients in the most efficient, cost-effective manner.

The firm’s extensive tax expertise includes a strong emphasis in numerous areas of civil tax disputes as well as defending criminal tax investigations and prosecutions. Our tax lawyers are routinely involved in complex civil tax examinations on behalf of wealthy individuals and closely held entities as well as large corporations involving both domestic and foreign tax related issues. 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 US government to identify undeclared interests in foreign financial accounts, voluntary disclosures (OVDP Streamlined Procedures and otherwise), sensitive issue civil tax examinations, criminal tax investigations and prosecutions.

The firm has represented literally hundreds and hundreds of US taxpayers participating in various IRS Offshore Voluntary Disclosure Programs (OVDP) Streamlined Procedures and other forms of voluntary disclosures regarding foreign financial account values far exceeding billions of dollars, in the aggregate. The firm has also represented numerous taxpayers involved in Grand Jury criminal tax investigations, criminal tax 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 background and experience of our tax lawyers derived from positions at the U.S. Department of Justice, Internal Revenue Service, U.S. Tax Court and private practice. Coupled with strong working relationships with these government agencies, we are fully capable to provide effective representation of our clients when facing the most complex or sensitive tax-related matters.

The firm authored the Tax Management Portfolio “Tax Crimes” (Pub. 636) (2d.) published by the Bureau of National Affairs. 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 as Chair of the Internal Revenue Service Advisory Council (IRSAC), the Advisory Board for the California Franchise Tax Board and the Advisory Council for the California State Board of Equalization.

Representatives of the firm routinely Chair conferences focused on offshore voluntary disclosures and defensive strategies to government examinations and criminal investigations and serve on prestigious committees of national, state and local bar and accounting associations and many are regular contributors to leading journals and publications involving tax matters. With respect to tax-related matters, few firms have the resources, relationships, expertise and collective experience offered by Hochman, Salkin, Rettig, Toscher & Perez.

Hochman, Salkin, Rettig, Toscher & Perez provides an innovative approach in its efforts to provide the highest quality legal services available. The firm is highly regarded for utilizing every resource available in the successful pursuit of the strategic and tactical objectives of its clients. The extensive knowledge and experience of each tax lawyer is enhanced by close collaboration within our various tax practice areas. Few other firms have the similar firm-wide depth of knowledge and experience necessary to effectively represent the interests of their clients in these areas.

“Hochman, Salkin, Rettig, Toscher & Perez, P.C., is internationally recognized as the preeminent tax law firm in the Western United States. The reputation of the firm for excellence and integrity in the tax community is unparalleled.”
Chambers & Partners, 2018