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Tax Controversy and Litigation
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Is the IRS Watching You?

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…

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The Importance of Amending Your Partnership and LLC Agreements

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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Inspector General: Gaps in IRS Tax Preparer Liability Strategy

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…

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Final Section 199A Regulations: Interpretation of W-2 Wages and UBIA Thresholds May Significantly Limit the QBI Deduction

When it was announced that the Tax Cuts and Jobs Act included a new 20% deduction for qualified business income (“QBI”) of pass-through businesses, many business owners started planning for huge tax savings.  Hopefully, their exuberance was not misplaced and was based on a thorough review of the new tax law.  Aside from many types…

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Final Section 199A Regulations: Safe Harbor Created By Notice 2019-07 Brings Additional Certainty on Application of QBI Deduction to Rental Real Estate Enterprises

Along with the recent issuance of regulations under section 199A of the Internal Revenue Code (“I.R.C.”), the Internal Revenue Service (“the Service”) also published a revenue procedure setting forth a safe harbor under which rental real estate will be treated as a “trade or business” pursuant to I.R.C. § 199A.  For those in the real…

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Section 199A: How “Reasonable Compensation” Will Be Defined and How it May Impact the QBI Deduction

From its inception, Section 199A made it fairly clear that the deduction for qualified business income (“QBI”) would not apply to all income in respect of pass-through businesses.  Aside from limitations dependent on the nature of the industry (i.e., the “specified service trade or business” provisions of I.R.C. § 199A(d)(2)), the total wages paid to…

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Final Section 199A Regulations: Tax Planning for Businesses with Gross Receipts from Both Specified Services and Non-Specified Services

Although Section 199A will reduce the tax burden for many owners of pass-through businesses, classification as a “specified service trade or business” (“SSTB”) can severely limit its application for many others.  While certain businesses will find it extremely difficult, if not impossible, to avoid such a classification (e.g., law firms, accounting firms, consulting firms), there…

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Final Section 199A Regulations: Initial Takeaways on Clarification of Definition of “Specified Service Trade or Business”

Since the passage of the Tax Cuts and Jobs Act, business owners and tax practitioners alike have focused on the potential effect of Section 199A.  Though it has been clear for some time that the 20% deduction afforded to those with “qualified business income” would be a boon for businesses structured as pass-through entities, it…

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Tax Audits for Cash Businesses

Cash businesses generally do not leave the detailed paper trail that would enable a straightforward audit of gross income, expenses, and profits. Nonetheless, businesses that operate on a cash basis develop their own methodologies to track their revenues. The IRS, however, has its own auditing standards and methodologies for cash businesses. Discrepancies between those two…

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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