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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…

Keep Your Business and Personal Finances Separate

Sep 27, 2019

Incorporating your closely-held business is one of the best strategies you can use to shield your personal assets from liabilities that might arise in that business. If, however, you fail to keep your business and personal finances separate, a person who has a claim against your business can break through the barriers that are created…

Eighteen Rosenberg Martin Greenberg, LLP Attorneys Selected for Inclusion in Baltimore Best Lawyers in America 2020

Aug 15, 2019

Rosenberg Martin Greenberg, LLP is proud to announce that 18 of its attorneys have been selected by their peers for inclusion in the Best Lawyers® in America 2020 List, to be featured in U.S. News & World Report. Best Lawyers® is a respected peer-review publication in the legal profession which has been published for over…

The Crackdown on Cryptocurrency

Michael J. March | Aug 1, 2019

We all read the headlines. Virtual currencies are a hot button topic. Even Facebook is developing its own virtual currency. It is easy to understand the attraction, for some. The use of a virtual currency is anonymous. Account holders are protected behind private passwords and encrypted files…or so we may have thought. Over the next…

Collection: Disputing a Notice of Federal Tax Lien Before It Is Filed

Giovanni V. Alberotanza | Jul 15, 2019

I. Introduction Internal Revenue Service (“IRS”) bank account levies and wage garnishments count among the scariest tax collection weapons in the U.S. Treasury arsenal. However, the Notice of Federal Tax Lien (“NFTL”) can, in many cases, pose a more immediate and substantial threat to individuals and businesses with outstanding tax liabilities. In January 2018, the…

Collection: When Uncle Sam Crosses the Border: What is in the IRS International Collection Toolbox?

Giovanni V. AlberotanzaMichael J. March | Jul 15, 2019

This article was originally published in the Journal of Tax Practice and Procedure, April – May 2019 edition. The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include locating and contacting the taxpayer, the increasing complexity of international…

Is the IRS Watching You?

Michael J. March | Jul 10, 2019

The year is 2010. Toy Story 3 tops the box office, the New Orleans Saints are Super Bowl Champions, and President Obama signs into law the Patient Protection and Affordable Care Act. That same year, the Internal Revenue Service (“IRS”) had a whopping $13.75 billion budget.[i] Fast forward to 2018. The IRS budget has been…

The Importance of Amending Your Partnership and LLC Agreements

Jun 28, 2019

The Bipartisan Budget Act of 2015 (the “BBA”) has been on the books for three years, but new rules for partnership audits and adjustments only recently became effective for the 2018 tax filing year. The tax attorneys at Rosenberg Martin & Greenberg LLP in Baltimore are now advising partnerships and limited liability companies to review…

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Phone: 410-727-6600
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