Tax Controversy and Litigation
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Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary Disclosure Program

Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance November 30, 2018 On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important updates regarding its Voluntary Disclosure Practice (“the Memo”).  Although the Memo provides significant guidance as a result of the closing of the Offshore…

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Coinbase and the IRS: The Takeaway for Virtual Currency Investors (Comply with Tax Obligations or Face Real Consequences)

On November 28, 2017, a federal judge in California ordered Coinbase, Inc. (“Coinbase”), a major virtual currency exchange, to provide the Internal Revenue Service (“the Service”) with account information for thousands of individuals trading virtual currency through its exchange.  (A copy of the entire Order in United States v. Coinbase, Inc., et al., No. 17-cv-01431-JSC…

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Do I Have to Pay Taxes on Income Earned Abroad?

Modern technology and transportation have opened up literally a world of opportunity and the result is that many Americans earn income from foreign entities. It is important for anyone in this situation to understand that both resident aliens and U.S. citizens, whether stateside or abroad, are subject to United States taxing system and must report…

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Day Trading: Understanding Common Issues and Pitfalls Can Increase Return on Investment

Technological advances have greatly improved access to financial information and likewise improved the ability for many Americans to trade for their own accounts.  While most casually trade a few securities for pleasure, a growing number engage in high-volume trading.  These traders may perform adequate research on their investments before engaging in these transactions; however, not…

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Foreign-Owned Domestic Disregarded Entities Face New Reporting Rules

The Treasury Department and the Internal Revenue Service recently finalized a notable shift in the way foreign-owned domestic disregarded entities are treated for tax purposes; changes which impose new reporting requirements with which compliance must be achieved. The tax professionals at Rosenberg Martin Greenberg can help provide entities impacted by these rules with legal counsel…

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What Penalties Are Associated with IRS Foreign Account Reporting Rules?

What obligations are imposed by the IRS on those who hold foreign accounts or other types of foreign assets? The Maryland tax lawyers at Rosenberg Martin Greenberg are committed to helping clients navigate the complexities of foreign account reporting rules and avoid potentially costly penalties. Reporting of foreign bank accounts and other assets American taxpayers who hold…

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I reported my foreign financial accounts on my individual income tax return that I filed this past April. Am I done with my reporting requirements for the year?

Maybe.  If you are a United States person and have a financial interest in or signature authority over a foreign financial account, then you must also report your foreign financial accounts on Financial Crimes Enforcement Network (FinCEN) 114, Report of Foreign Bank and Financial Accounts (FBAR) if the aggregate value of all of your foreign…

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Panama Papers Highlights Need For American Tax Compliance

On April 3, the International Consortium of Investigative Journalists (ICIJ) published what is now known around the world as the Panama Papers. These leaked documents – more than 11 million of them, comprising 2.6 terabytes of data – come from Mossack Fonseca, a top Panama law firm, and reveal secret offshore accounts and shell companies…

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I received a letter from my foreign bank about FATCA and my connections with the U.S. Why did they send this letter and what should I do?

The Foreign Account Tax Compliance Act (“FATCA” (pronounced “Fat-cuh”)) is a U.S. law that went into effect in July, 2014.  FATCA requires foreign financial institutions (“FFIs”) to report information to the U.S. government about its account holders that may have a U.S. income tax reporting requirement (often referred to as a “U.S. fiscal status”).  An…

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Phone: 410-727-6600
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Rosenberg Martin Greenberg

705 Melvin Avenue Annapolis, MD 21401
Phone: 410-727-6600
Map & Directions