HoweyCoin—Too Good To Be True
“If you’ve ever been tempted to buy into a hot investment opportunity linked with luxury travel, the Securities and Exchange Commission has a deal for you.” Sound too good to be true? It is. This announcement was made in the May 16, 2018 U.S. Securities and Exchange Commission (SEC) press release which was issued to […]
Release or Withdrawal of Federal Tax Lien: Which is Better?
When you fail to pay the taxes you owe to the government after the Internal Revenue Service sends you a bill with an explanation for how much you owe, the tax collection agency could place a lien against your property. This lien essentially protects the government’s interest in your property, which could include personal property, […]
IRS Responds to States’ Attempts to Circumvent SALT Cap
On May 23, 2018, the IRS issued Notice 2018-54,[1] making it abundantly clear that when it comes to state efforts to circumvent the recently enacted state and local tax (SALT) deductions cap, “taxpayers should be mindful that federal law controls the proper characterization of payments for federal income tax purposes.” Section 164 of the Internal […]
New Tax Laws in Maryland in Response to Federal Tax Reform
On May 15, 2018, Maryland enacted laws which are projected to counteract the recent federal tax reform’s negative effects on a significant portion of Maryland taxpayers. Recent estimates issued by the Comptroller’s office indicated that 23% of Maryland taxpayers would experience an increase in their state and local taxes due to the new federal code […]
District Court Maintains $100,000 Regulatory Cap for Willful FBAR Violations
On May 16, 2018, in United States v. Colliot,[1] the District Court for the Western District of Texas held that the Internal Revenue Service (IRS) is precluded from assessing a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty exceeding the $100,000 limit provided in Federal Regulation (Reg.) §1010.820. The decision is a victory […]
Notice CC-2018-005: How Chief Counsel Attorneys Handle Passport Actions
On April 5, 2018, the Chief Counsel’s Office provided advice in Notice CC-2018-005 to Chief Counsel attorneys who handle I.R.C. §7345 passport actions. The Chief Counsel’s Office detailed both the certification and reversal processes for “seriously delinquent taxpayers,” as well as the procedures for the judicial review of certifications. Lastly, the Notice indicates that since […]