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Tax Controversy News

When Will You Get Your 2018 Tax Refund?

Apr 9, 2019

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…

Maximizing Aggregation Rule Benefits for Business and Rental Properties

Apr 9, 2019

Taxpayers who own business or rental properties will have legitimate questions about the aggregation rules for Section 199A of the Tax Cuts and Jobs Act of 2017. The tax attorneys at Rosenberg Martin & Greenberg LLP in Baltimore note that the IRS did not issue guidance for Section 199A issues until mid-January 2019. Taxpayers are…

Collection – Pre-Notice Levies: When the IRS Can Levy Before Notifying Taxpayers of Their Right to a Hearing

Giovanni V. AlberotanzaMichael J. March | Mar 28, 2019

This article was originally published in the Journal of Tax Practice and Procedure, December 2018 – January 2019 edition. A. Introduction One of the most important rights a taxpayer has during the Internal Revenue Service (“IRS”) administrative collection process is to be notified of their right to a collection due process hearing before the IRS…

How to Stop IRS Wage Garnishment

Mar 25, 2019

One of its most effective tools the IRS has for the enforcement of tax payment is wage garnishment. Ben Franklin is noted as saying, “an ounce of prevention is worth a pound of cure” and that advice holds true here – it is always better to prevent an IRS garnishment before it starts. But even…

Inspector General: Gaps in IRS Tax Preparer Liability Strategy

Mar 25, 2019

According to a recent report by the U.S. Treasury Inspector General for Tax Administration, the IRS lacks a uniform strategy to hold accountable unregulated tax preparers who commit misconduct. The report was released on July 25, 2018, and it calls on the IRS to better use its resources to identify and respond to tax preparers…

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other foreign financial assets?

Brandon N. Mourges | Mar 20, 2019

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States persons – U.S. citizens or those residing in the U.S.  A selection of these provisions and the attendant potential penalties are…

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

Brandon N. Mourges | Mar 13, 2019

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,…

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

Brandon N. Mourges | Mar 6, 2019

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…

Can Cannabusinesses Qualify for the New Tax Incentives in Opportunity Zones?

Brandon N. Mourges | Mar 5, 2019

One of the key provisions of the Tax Cuts and Jobs Act of 2017 was the creation of additional tax incentives for investment in opportunity zones.  For those with significant unrealized gains, the potential deferral or elimination of gains permitted with the additional of section 1400Z to the Internal Revenue Code can be a windfall. …

Are Owners of Cannabusinesses Eligible for the Qualified Business Income Deduction Under Section 199A?

Brandon N. Mourges | Feb 28, 2019

Section 199A of the Internal Revenue Code, introduced by the Tax Cuts and Jobs Act (“TCJA”), created an opportunity for business owners to substantially lower their income taxes.  Subject to many qualifications, beginning in 2018, business owners were potentially eligible for up to a 20% deduction on “qualified business income” (“QBI”).  For those owning a…

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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
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