Tax Controversy News

Important Tax Dates for the 2020 Calendar Year

Jan 24, 2020

Every year, the IRS announces the opening date for when it will begin to accept tax returns from the previous tax year. This year, the IRS will begin processing 2019 returns on January 27, 2020. Taxpayers who file their 2019 returns electronically before the January 27 date will not receive any preference over filers who…

Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary Disclosure Program

Brandon N. Mourges | Jan 21, 2020

Now, More than Ever, Taxpayers with Lingering Offshore TaxNon-Compliance Must Seek Professional Assistance On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important updates regarding its Voluntary Disclosure Practice (“the Memo”).  Although the Memo provides significant guidance as a result of the closing of the Offshore Voluntary Disclosure Program (“OVDP”), which ended…

Collection: Expatriation with No Tax, Interest or Penalties: New Relief Procedures for Certain Former Citizens

Giovanni V. Alberotanza | Jan 6, 2020

This article was originally published in the Journal of Tax Practice and Procedure, August – September 2019 edition. Introduction On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010.1 Under the new IRS Relief Procedures,…

Responding to Correspondence from the IRS

Dec 17, 2019

A collection letter from the IRS is not necessarily bad news, but the recipient’s response can turn that letter into a negative experience. The worst reaction would be to ignore the message. The better course of action is to consult with a tax attorney who can help you develop an appropriate response. The tax lawyers…

Calculating and Paying Your Estimated Quarterly Taxes

Dec 17, 2019

If you make quarterly estimated tax payments on income that you receive from freelance services, stock dividends, or rental properties, you want your estimates to be as accurate as possible. If you overestimate your tax obligation, you give the government an interest-free loan, but if you underestimate that liability, you may be required to pay…

Nineteen Rosenberg Martin Greenberg Lawyers Honored by Maryland Super Lawyers in 2020

Dec 6, 2019

Rosenberg Martin Greenberg is proud to announce that nineteen of its attorneys have been selected for inclusion in the 2020 edition of Maryland Super Lawyers®. The firm’s attorneys who have been selected include Benjamin Rosenberg, Gerard Martin, Barry Greenberg, Gerard Gaeng, Andrew Baida, Louis Ebert, William Hallam, David Wyand, Jonathan May, Charles Curlett, Jr., Steven…

Benchmark Litigation Highly Recommends Rosenberg Martin Greenberg, LLP

Dec 6, 2019

For the twelfth year in a row, the 2020 edition of Benchmark: America’s Leading Litigation Firms and Attorneys lists Rosenberg Martin Greenberg, LLP among their top litigation firms in Maryland.  The firm is proud that its litigation group has received Benchmark’s top rating of “Highly Recommended,” and seven of its partners have been listed as…

New Guidance from the Internal Revenue Service on Cryptocurrency: Rev. Rul. 2019-24 Clarifies the Agency’s Position on Hard Forks and Airdrops

Brandon N. Mourges | Oct 18, 2019

On October 9, 2019, the Internal Revenue Service (“the Service”) published further guidance regarding the tax treatment of cryptocurrency.  This marks the first time since 2014 that the Service has provided insight into the taxation of this fast-evolving area. In Rev. Rul. 2019-24, the Service specifically discussed whether and how “hard forks” or “airdrops” could…

IRS Scam Alert

Sep 27, 2019

Computer hackers are actively taking advantage of the fears that most people feel when they see a communication from the IRS. Multiple businesses and individuals in 2019 have received emails and other electronic notices that purport to be from the IRS, when they are in fact, targets of a massive scam. When the recipients follow…

Cost Sharing Tax Disputes

Sep 27, 2019

Multinational corporations use cost-sharing arrangements (“CSA’s”) to spread costs between a parent and one or more offshore subsidiaries. Aggressively structured, CSA’s might exclude the value of stock-based compensation from shared costs, which can have the effect of increasing the compensation deduction that a company is entitled to claim on its domestic corporate returns. Because higher…

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