Tax Controversy and Litigation
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When Will You Get Your 2018 Tax Refund?

The extended government shutdown is adding to the anxiety that some taxpayers feel with respect to when they will get their refund. The tax attorneys at Rosenberg Martin & Greenberg LLP cannot answer that question with any degree of certainty. We can, however, provide some guidance that will help taxpayers avoid the problems that can…

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Can a Prenuptial Agreement Executed Before January 1, 2019 Preserve Deductibility of Alimony Payments Relating to Divorce Decrees Entered After That Date?

The Tax Cuts and Jobs Act of 2017 (“TCJA”) did away with the long-standing provision allowing for deductions of alimony payments by the payor.  Specifically, the TCJA adopted the prior definition of “alimony and separate maintenance payment” under the Internal Revenue Code but eliminated deductibility for any “divorce or separation instrument” executed after December 31,…

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IRS Reminds Taxpayers of Its Ability to Revoke Passports and Deny Passport Applications: What You Need to Do If You Plan to Travel Abroad and Have Unpaid Federal Taxes

Last week, the Internal Revenue Service (“IRS”) published another friendly reminder that it was recently vested with the authority to revoke passports and deny passport applications for those with “seriously delinquent tax debts.”  Within that notice, the IRS reminded taxpayers that they may not be able to obtain or renew passports if they owe federal…

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Final Section 199A Regulations: Interpretation of W-2 Wages and UBIA Thresholds May Significantly Limit the QBI Deduction

When it was announced that the Tax Cuts and Jobs Act included a new 20% deduction for qualified business income (“QBI”) of pass-through businesses, many business owners started planning for huge tax savings.  Hopefully, their exuberance was not misplaced and was based on a thorough review of the new tax law.  Aside from many types…

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Final Section 199A Regulations: Safe Harbor Created By Notice 2019-07 Brings Additional Certainty on Application of QBI Deduction to Rental Real Estate Enterprises

Along with the recent issuance of regulations under section 199A of the Internal Revenue Code (“I.R.C.”), the Internal Revenue Service (“the Service”) also published a revenue procedure setting forth a safe harbor under which rental real estate will be treated as a “trade or business” pursuant to I.R.C. § 199A.  For those in the real…

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Section 199A: How “Reasonable Compensation” Will Be Defined and How it May Impact the QBI Deduction

From its inception, Section 199A made it fairly clear that the deduction for qualified business income (“QBI”) would not apply to all income in respect of pass-through businesses.  Aside from limitations dependent on the nature of the industry (i.e., the “specified service trade or business” provisions of I.R.C. § 199A(d)(2)), the total wages paid to…

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Final Section 199A Regulations: Tax Planning for Businesses with Gross Receipts from Both Specified Services and Non-Specified Services

Although Section 199A will reduce the tax burden for many owners of pass-through businesses, classification as a “specified service trade or business” (“SSTB”) can severely limit its application for many others.  While certain businesses will find it extremely difficult, if not impossible, to avoid such a classification (e.g., law firms, accounting firms, consulting firms), there…

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Final Section 199A Regulations: Initial Takeaways on Clarification of Definition of “Specified Service Trade or Business”

Since the passage of the Tax Cuts and Jobs Act, business owners and tax practitioners alike have focused on the potential effect of Section 199A.  Though it has been clear for some time that the 20% deduction afforded to those with “qualified business income” would be a boon for businesses structured as pass-through entities, it…

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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