Tax Controversy and Litigation
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Responding to an IRS Letter 5935 and IRS Form 15023: What to Do (and Not Do) to Resolve Your Offshore Tax Issues

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”) or who submitted a voluntary disclosure letter within the OVDP.  For those that receive these letters – IRS Letter 5935 and IRS Form 15023…

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Planning to Travel Abroad? Don’t Let the IRS Stop You at the Border. Understanding Recent Guidance Regarding Passport Revocation Rules Under I.R.C. § 7345

As part of the Fixing America’s Surface Transportation Act (“FAST Act”) of 2015, Congress mandated that the State Department deny any passport application for an individual, or revoke any previously issued passport for an individual, if the Internal Revenue Service (“the Service”) certifies that the individual has a “seriously delinquent tax debt.”  In early 2018,…

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Maryland State Lawmakers Propose Bills to Reduce Taxes

The recently-unveiled federal tax plan promises to lower the taxes of most Americans, but a significant portion of Marylanders do not fall within that group. Instead, state legislators estimate that 92 percent of Maryland residents will pay more in taxes because of the change, amounting to as much as $1 billion in additional federal taxes…

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Brewing Interest: How Tax Changes Will Help to Grow the Craft Brew, Winery, and Distillery Industries

While the Tax Cuts and Jobs Act of 2017 (“the Act”) affects many small businesses, alcohol producers are among the few industries that have been specifically targeted for relief.  In addition to rate changes and additional deductions that are available many businesses, the Act benefits craft breweries, wine producers, and distilleries by temporarily reducing the…

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Tax Planning 101 with 529 Plans: How Marylanders Can Reduce Annual Private School Costs by $895 Per Child*

As a result of the tax reform of 2017, the application of qualified tuition programs (“529 Plans” has been broadened dramatically.  By coupling the federal tax benefits of 529 Plans with existing Maryland tax provisions, Marylanders may be able to use these plans to reduce the cost of private secondary education by roughly $895 per…

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Will the New Tax Plan Result in More Divorces in 2018? Eliminating Deductibility of Alimony Payments May Fast-Forward Some Divorces

One of the many changes contained within the Tax Cuts and Job Act of 2017 (“the Act”) may prove to be a boon for divorce (and tax) attorneys in 2018.  As explained in more detail below, section 11051 of the Act does away with the long-standing provision that allowed for the deductibility of alimony payments. …

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For Those Solicited for Tax Saving Schemes, Heed Your Parents’ Advice: If It Sounds Too Good to Be True, It Probably Is!

With the end of the year approaching and tax changes on the horizon for 2018, many business owners and investors are seeking creative ways to minimize their current and future tax burdens.  While some plans are legally sound and others may appear aboveboard, at least on their face, taxpayers should remember the age-old adage: “If…

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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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As If! Restitution Order Does Not Permit the IRS to Collect Penalties and Interest without First Assessing a Tax Liability

On October 3, 2017, the United States Tax Court issued an opinion in Klein v. Commissioner, 149 T.C. No. 15,[1] which creates a potential roadblock for the Internal Revenue Service (“the Service”) in civil cases stemming from criminal matters.  In particular, the Tax Court held that the Service cannot use a criminal order of restitution…

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Rosenberg Martin Greenberg

25 South Charles Street, 21st Floor MD 21201
Phone: 410-727-6600
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Rosenberg Martin Greenberg

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