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Maryland District Court Holds the IRS Tax Lien Does Not Attach After Fraudulent Conveyance Set Aside under MUFCA

In a recent case,[1] the Federal District Court for the District of Maryland held that the U.S.’s federal IRS tax lien did not attach to a piece real property after the transfer to the taxpayer was voided under the Maryland Uniform Fraudulent Conveyance Act (“MUFCA”).[2] Facts Transfer from Insolvent Estate Plaintiff, BG, is a nursing…

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Maryland Tax Court Holds Minority Member Partially Liable for Unpaid Income Tax Withholding

Overview In Judge v Comptroller, No. 17-IN-00-0724 (Sept. 25, 2018)(link), the Maryland Tax Court overturned the Maryland Comptroller’s finding that Petitioner was personally liable for Maryland income tax withholdings for the period after the Petitioner was no longer involved in the business operated by a Maryland limited liability company (“LLC”). Background At issue was the…

Maryland’s Sales Tax Holiday for Qualifying Energy Star Appliances Returns For 2017

Maryland’s Sales Tax Holiday for Qualifying Energy Star Appliances Returns For 2017

From Saturday, February 18, 2017 through Monday, February 20, 2017 (i.e., Presidents’ Day Weekend), consumers will not pay the state’s 6% sales tax on qualifying ENERGY STAR appliances.  In order to be exempt the item must both be a “qualifying item” and bear the Energy Star label. Per the Comptroller’s website (link), the following types…

Judge Compares Nordstrom’s IP Holding Company State Tax Play to Maligned Basketball Strategy

Judge Compares Nordstrom’s IP Holding Company State Tax Play to Maligned Basketball Strategy

On Monday August 18, 2014, the Maryland Court of Appeals released its decision in NIHC v. Comptroller of the Treasury.[1] The counsel for Nordstrom must have known that things were not going to go their way when the opinion’s opening paragraph analogized their client’s “intellectual property holding company” (”IPHC”) tax planning to the historically successful,…