irstaxlitigation Blog

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 […]

The IRS Is Receiving Thousands of Coinbase Users’ Information

In November of 2017, Coinbase, Inc. (“Coinbase”), a company that facilitates digital currency transactions, was ordered to comply with an IRS summons demanding specific Coinbase client identifying information and transaction data for Coinbase accounts “with at least the equivalent of $20,000 in any one transactions type” in any year during the period of 2013-2015.[1] Approximately […]

Baltimore Police Commissioner De Sousa Charged With Tax Crime

On May 10, 2018, the United States Attorney for the District of Maryland announced that new Baltimore Police Commissioner Daryl De Sousa has been charged with three misdemeanor counts of willful failure to file a U.S. individual income tax return. Specifically, the charges allege that Commissioner De Sousa failed to file returns for tax years […]

The Domestic Asset Protection Trust

What if you could take a portion of your hard-earned wealth, lock it up from your creditors, but keep the key for yourself? It sounds too good to be true, but the Domestic Asset Protection Trust provides a very real and very valuable estate planning tool for achieving this objective.   The Domestic Asset Protection […]