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Tax Controversy News

Jun 5, 2018

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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May 8, 2018

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…

May 2, 2018

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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Rosenberg Martin Greenberg

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Phone: 410-727-6600
Map & Directions