Sanford Millar – Law Offices of Sanford I. Millar

When the Fifth Amendment Privilege Doesn't Work-Tax Cases

A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. …more
| Constitutional Law, Finance & Banking, Taxation

State Offshore Voluntary Disclosure Laws Surveyed

The IRS and the states have mutual exchange of information agreements. The agreements are often bi-directional, so that state information about audit results, often including sales tax audits, is provided to the IRS just as IRS…more
| Taxation

IRS v. Medical Marijuana: IRS 1 Medical Marijuana 0

The Internal Revenue Code may be the single strongest enforcement weapon in the battle over legal sale and distribution of "medical marijuana". The Opinion of the United States Court of Appeals for the Ninth Circuit, Oliver v…more
| Business Organizations, Conflict of Laws, Taxation

An Immigration Story

I have never used this Newsletter to express my views outside taxation issues, but current events have caused me to change my approach for this single occasion. Please allow this indulgence. Just after American troops…more
| Immigration Law

How Does the IRS Determine if Conduct is "Willful" or "Non-Willful"?

This Article is a guide for practitioners and taxpayers in deciding whether to apply for the streamline procedures of the IRS's Offshore Voluntary Disclosure Program ("OVDP"). The streamline procedures require a certification of…more
| Finance & Banking, International Law & Trade, Taxation

Delinquent FBAR Reporting and How to Come Forward? Fact and Choice of Method Really Matter!!!

FBARS for 2014 are Due and MUST BE FILED by June 30, 2015 - There are three approaches to coming forward and filing delinquent FBAR's (Report of Foreign Financial Account). They are..…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Domestic Voluntary Disclosure as an Alternative to Indictment

The United States Attorney for the Southern District of New York announced that the - "Owner and operator of DNS Construction Corporation, was sentenced today in Manhattan federal court to a term of five years of…more
| Criminal Law, Labor & Employment Law, Taxation

U.S. Department of Justice States its Tax Enforcement Priorities

In her recent testimony before Congress Caroline Ciraolo Acting Assistant Attorney General stated the enforcement priorities for the Tax Division. Among the the four areas of focus is Offshore Tax Evasion. "Combatting the…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Uses of Suspicious Activity Reports by the IRS

In a recent conference the Director of the Financial Crimes Enforcement Network (FinCen) discussed the use of Currency Transaction Reports (CTR's) and Suspicious Activity Reports (SAR's) which are required to be filed by…more
| Business Organizations, Finance & Banking, International Law & Trade, Securities Law, Taxation

Marijuana and the Tax Apocalypse

As Californians evaluate the potential for legalization of Marijuana it is important to consider the current state of conflict between state and federal laws and regulations regarding the production, distribution and sale of…more
| Business Organizations, Conflict of Laws, Finance & Banking, Taxation

Bad News About Unfiled FBARs, Another Indictment

A recent indictment by the United States Attorney's office in California illustrates the inter-relationship between curency transfer restrictions, (such as those involving Iran), foreign financial account reporting (the FBAR…more
| Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Swiss Bank Settlements-What's Next for U.S. Taxpayer's?

The Department of Justice has released the signed Non-Prosecution Agreement NPA) with Swiss bank BSI SA. The Non-Prosecution Agreement is likely the precursor to enhanced enforcement efforts by the DOJ and IRS against those…more
| Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Warning, Offshore Accounts Holders May Have No Fifth Amendment Protections

In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the "required records doctrine" to compel taxpayer's to produce what may be incriminating evidence of ownership or control of…more
| Civil Procedure, Criminal Law, Finance & Banking, International Law & Trade, Taxation

Cash Businesses Must Maintain Records

A recent Tax Court case (Kunkle v. C.I.R.) reiterates the need for cash businesses to maintain proper books and records. "Section 6662 imposes a 20% penalty upon the portion of any underpayment attributable to (among…more
| Business Organizations, Commercial Law & Contracts, Taxation

DOJ Warns Against Wrongful Use of Streamline Procedures

The U.S. Department of Justice is considering actions against taxpayers who wrongfully used the Streamlined Procedures to assert non-willful conduct. As quoted in Tax Notes Today..…more
| Commercial Law & Contracts, International Law & Trade, Taxation
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Contact

1900 Avenue of the Stars Suite 650
Greater Los Angeles Area, California 90067, United States

  • 310-556-3007
  • 310-556-3094

Areas of Practice
  • Business Organizations
  • Taxation
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