Tax Controversy and Litigation
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Colliot and Its Effect on Penalties for Potential FBAR Violations: Ruling Provides for Significant Limitation on Amount of Penalties

On May 15, 2018, the United States District Court for the Western District of Texas issued an important ruling concerning the application of willful FBAR penalties under 31 U.S.C. § 5321.  In United States v. Colliot, Case No. AU-16-CA-01281-SS (W.D. Tex. 2018), the court held that the Internal Revenue Service (“the Service”) could not assess…

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Who Qualifies for This Massive Tax Break?

Small and medium sized businesses (SMBs) were quick to cheer the new 20% deduction on pass through income that Congress included in the new tax law. As with so many tax and legal issues, however, the devil is in the details. The tax attorneys at the Baltimore law firm, Rosenberg Martin Greenberg LLP, note that…

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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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Continuing an Annual Trend, Comptroller Opens Tax Season by Suspending Tax Preparers

On February 2, 2018, the Comptroller issued a press release announcing that he has suspended the processing of electronic tax returns for nine additional tax preparers.  A copy of the press release can be found here.)  The Comptroller acknowledged that these preparers were suspended based upon technology designed to spot instances of fraud used by…

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Tax Changes for Nondisclosure Agreements Relating to Sexual Harassment and Sexual Abuse Lawsuits May Have Consequences for All Parties Involved

For those litigating cases involving alleged sexual harassment or sexual abuse, the Tax Cuts and Jobs Act of 2017 (“the Act”) made an important change that might easily be overlooked.  In pertinent part, Section 13307 of the Act amends Section 162 of the Internal Revenue Code (relating to the deductibility of trade or business expenses)…

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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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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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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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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