Taxation

Whiteford, Taylor & Preston's Tax group includes practitioners who focus on all aspects of the Federal Internal Revenue Code, its regulations, and its administrative and judicial interpretations.  We represent corporations, limited liability companies, partnerships, nonprofit organizations and individuals on questions dealing with income taxes, ERISA and pension benefits, estate and gift taxes, and international taxation. In addition, we have state tax law practitioners with experience in state and local tax matters, including income, sales, inheritance and property taxes.

Income and other taxes

Members of the group have extensive experience in advising businesses, individuals and non-profit organizations on a broad range of federal, state and international tax issues. For example, we guide business clients from initial start-up through maturity on all aspects of tax issues in order to enhance the tax efficiency of their activities and transactions, to limit their exposure to controversy, and to help them comply with federal, state and local tax laws. Members of our Tax Section also have substantial experience representing clients in controversy matters, including administrative appeals, litigation of state tax matters in state courts (including income and sales tax issues, nexus for income or sales tax purposes, property tax, utility and franchise tax issues), and federal tax matters in federal courts.

The attorneys in our Tax Section work closely with attorneys in our corporate and securities, real estate, litigation and employment law sections. By using this team-oriented approach, we can more comprehensively represent a wide range of clients, including sole proprietorships, closely-held businesses, partnerships, joint ventures and limited liability companies, middle market and public companies, non-profit organizations and foreign entities.

Members of our Tax Section have achieved national prominence in their areas of practice. They are active in state and federal bar associations. Three of our attorneys are past chairs of the Maryland State Bar Association's Tax Section. Members of the firm are frequent speakers at seminars on current tax issues and have been course instructors at the Graduate Tax Programs of local universities.

Employee Benefits and ERISA

Our Employee Benefits and ERISA lawyers provide advice and legal services to private sector, government and tax-exempt or not-for-profit clients on issues relating to their employee pension plans, welfare plans, deferred compensation, executive compensation arrangements, and fringe benefits. Generally, legal issues arise in connection with compliance with the Employee Retirement Income Security Act of 1974 ("ERISA"), various requirements in the Internal Revenue Code for tax qualification of pension plans or for tax preferred treatment of executive benefit programs, welfare plans and fringe benefit arrangements and under state laws and regulations. The group’s experience is described in more detail here.

Estate and Gift taxes

Our estate and trust lawyers can help you consider the impact of  federal and state estate and gift taxes related to your estate, whether it involves traditional planning or more complex issues, such as complex family structures or closely-held business interests, and advise you on how your assets can pass to your beneficiaries in the most tax-efficient and cost effective manner. The group's practice is described in more detail here.

Real Estate taxes

Our tax lawyers work closely with our real estate attorneys to structure transactions in the most efficient manner, taking into account the federal and state income tax impact on the parties involved in the transaction, as well as the recordation and transfer tax implications. Read more about this practice here.

Nonprofit Organizations

We provide sophisticated and comprehensive advice on federal and state tax matters of particular relevance to associations, charities and other types of nonprofit organizations.  For example, we counsel and represent nonprofit clients on matters such as obtaining and maintaining recognition of tax-exempt status, unrelated business income analysis, and structuring of subsidiaries, affiliates and joint ventures.  Our nonprofit clients include professional and trade associations, healthcare providers, educational institutions, and seniors' housing and care providers.  Read more about our Nonprofit services here.  

Tax-Exempt Finance

The firm's public finance lawyers have served as bond counsel, underwriter's counsel, borrower's counsel, trustee's counsel and guarantor's counsel in tax-exempt general obligation bonds and revenue bonds, as well as other forms of financing. For a full description, click here.

International tax

WTP has significant experience confronting the array of international tax issues faced by U.S. individuals and companies with income or operations abroad, as well as foreign individuals and companies with income or operations in the U.S.  We advise these individuals and companies on the tax implications of their cross-border transactions, including mergers and acquisitions and related financing transactions, and international restructurings, dispositions and divestitures. For more details, please click here.

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Articles

What You Should Know About Qualified Opportunity Zones

The 2017 Tax Cuts and Jobs Act established the Qualified Opportunity Zone program to provide a tax incentive for private, long-term investment in economically distressed communities (Sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code). Investors in these programs can defer and, potentially, reduce tax on short or long term capital gains (“Gains”) by investing in a Qualified Opportunity Zone Fund (an “OZ Fund”).

Chamber seeks changes to Md.'s business tax structure

Whiteford, Taylor & Preston’s Herman Rosenthal, a Senior Tax Partner who serves as Co-Chair of the Maryland Chamber of Commerce Tax Policy Committee, spoke before the Maryland Economic Development and Business Climate Commission on Wednesday, September 9.  Appearing with Chamber of Commerce colleagues,  Rosenthal advised that the Commission could improve Maryland’s business climate by recommending certain major tax reforms and taking a position against combined tax reporting.  A full report appeared on the front page of the September 10 issue of The Daily Record.

IRS Releases Anticipated Guidance for 2012 Offshore Voluntary Disclosure Program; Announces New Compliance Procedures for Low-Risk U.S. Citizens Residing Abroad

In a continued effort to combat offshore tax evasion and increase international compliance, on June 26, 2012, the Internal Revenue Service  provided updated guidance to the 2012 Offshore Voluntary Disclosure Program (the “2012 OVDP”), and announced that new compliance procedures will be available for certain non-resident taxpayers effective September 1, 2012

Client Alert: June 30 Deadline for Foreign Bank Account Reporting (FBAR) Requirements

This is a reminder that U.S. taxpayers with a financial interest over foreign financial accounts exceeding $10,000 in the aggregate at any point during the 2010 tax year must file a Form TD F 90-22.1 with the Internal Revenue Service (IRS) by June 30, 2011. The form must be received by the IRS by such date rather than postmarked by such date. The IRS has recently expanded the group of persons subject to the filing requirement and has also provided a new opportunity for U.S. taxpayers to file FBARs for prior years without incurring penalties.

2003 Maryland Legislative Update: Part 2

Personal Representatives – Election for Modified Administration (10/1/03). Increases the availability of modified estate administration, providing a streamlined version of the probate process.

Modified Administration – Final Report and Distribution – Extension (10/1/03). The new Bill is intended to make modified administration more user friendly. Modified administration under prior law required that a final report be filed within 10 months after the appointment of the personal representative and that final distribution of the estate occur within 12 months. The prior law did not permit extensions and failure to meet either of the deadlines revoked modified administration, thereby requiring the filing of an inventory and account. The new Bill provides for a 90-day extension of both time limits if a consent is: (1) signed by the personal representative and by each interested person, and (2) is filed within 10 months after the appointment of the personal representative. This Bill applies to estates of decedents dying on or after October 1, 2003.

2002 Maryland Legislative Update, Part 2

Each year the Maryland Legislature enacts a number of laws which impact in various degrees on the personal and business lives of people living in or doing business in the State of Maryland. The General Assembly adjourned on April 8, 2002, and the Session actively concluded when the Governor enacted legislation into State law during four separate signing ceremonies on April 9, April 25, May 6 and May 16.

Events

News

Highly Regarded Tax Attorney Elizabeth Atkinson Joins Whiteford

Whiteford Taylor & Preston announced today that Elizabeth J. Atkinson, a tax attorney with over twenty-five years of experience providing legal counsel on complex business transactions and tax controversy matters, has joined the firm.

U.S. News Awards Top-Tier Rankings to 46 Whiteford Practices, Including 18 Nationally

Whiteford, Taylor & Preston is pleased to announce that U.S. News and World Report - Best Lawyers ® “Best Law Firms” has awarded the firm exemplary rankings for 2019.  Eighteen of the firm’s practices are ranked at the national level, including two practices with national Tier 1 rankings:  Litigation and Bankruptcy.  At the state level, an additional forty-six practices have been ranked in Maryland, Washington, D.C., and VA.

Whiteford, Taylor & Preston Recognized as National Tier 1 by U.S. News and World Report

The 2017 edition of U.S. News and World Report - Best Lawyers ® “Best Law Firms” has awarded Whiteford, Taylor & Preston LLP exemplary ratings in its seventh annual rankings of law firms.

Twenty of the firm’s practices were ranked at the national level, as well as thirty-seven in Maryland, ten in Washington, D.C., and two in Roanoke, VA.

Karen Syrylo to Present at Whiteford, Taylor & Preston and Watkins, Meegan, Drury's Computer Services Tax Event on March 11, 2008

The Maryland Chamber of Commerce's State Taxation Consultant Karen T. Syrylo will join the list of presenters for Whiteford, Taylor & Preston LLP and Watkins, Meegan, Drury & Company LLC's Computer Services Tax Event on Tuesday, March 11, 2008. Held on the eve of Maryland's hearings on measures to revise, limit or repeal the Computer Services Tax from 3:30 to 6:00 p.m. at WTP's offices (7 Saint Paul Street, Baltimore, MD 21202), the event will be moderated by Heather A.