Tax Topics

On November 20, 2019, the IRS posted a series of Frequently Asked Questions (FAQs) which includes much needed guidance regarding rental real estate in the context of the Qualified Business Income (QBI) deduction under Internal Revenue Code (IRC) §199A.1A few of the particularly noteworthy FAQs include: (1) when rental real estate is treated as a […]

A billionaire recently told his New York staff that he was closing shop and relocating to Florida. Although warmer winters may have played a role in the decision, the move was more likely motivated by an attempt to reduce the entrepreneur’s tax obligations. Why would tax obligations fuel a move across the country? The Tax […]

On April 30, 2019, Maryland Governor Larry Hogan signed a law providing that certain tax liens on certain real or personal property terminate 20 years from the date of assessment. Previously, a tax judgment lien in Maryland never expired. Indeed, in 2015, the Court of Special Appeals clarified in Comptroller of Maryland v. Shipe,1 that […]

United States citizens living outside of the United States may still owe taxes to the Internal Revenue Service (IRS). The IRS has strict and far reaching tax laws. Tax laws that often extend beyond the borders of the country. As a result, anyone with citizenship will likely need to file with the IRS. What if […]

The Internal Revenue Service (IRS) recently reminded taxpayers that even those living abroad likely need to file paperwork this tax season. In some cases, the government may require taxpayers to file additional paperwork. What else does the Treasury Department need? The agency may also require an additional form, the Report of Foreign Bank and Financial […]

The United States Internal Revenue Service (IRS) requires taxpayers to report foreign assets. A failure to do so can result in fines and even criminal charges. Although most people know about this requirement, not everyone knows exactly how to go about reporting these assets. This post will provide some basic information, including common tax forms […]

The allure of a foreign country calls to many United States citizens. Some fall in love with the views, the culture, the weather. Some choose to make their vacation destinations more than just an occasional stop, but rather invest in property and visit their personal paradise on a more regular basis. Ownership of property in […]

The Internal Revenue Service (IRS) requires those who hold an interest in or signature authority over a foreign account with a value over $10,000 at any point during the applicable tax year file the Foreign Bank Account Report (FBAR). A failure to do so can lead to both civil and criminal penalties. But how harsh […]

The Internal Revenue Service (IRS) recently provided guidance on the application of section 965(e) of the Code. This section applies specifically to those who receive income from “certain specified foreign corporations.” The law basically requires a transition tax on foreign earnings. Who must pay this tax? The IRS requires United States shareholders as well as […]

The United States of America filed suit against a taxpayer for his alleged “willful” violation of the requirement to report an interest in a foreign account. The government had already established the taxpayer was required to file a Report of Foreign Bank and Financial Accounts (FBAR). The court is asked to determine which standard of […]