Sanford Millar
Law Offices of Sanford I. Millar

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1900 Avenue of the Stars
Suite 650
Greater Los Angeles Area, California 90067, United States
Phone: 310-556-3007
Fax: 310-556-3094
Areas of Practice
  • Business Organizations
  • Taxation

Government Refuses to Define "willfulness" for FBAR Purposes

Whether a taxpayer's conduct in failing to report foreign financial accounts is "willful" or "non-willful" makes a huge difference in penalty determination. However the government refuses to publish a definition of…more
 /  Finance & Banking, International Law & Trade, Taxation

Properly structured foreign gifts of real property property can be estate and gift tax free

The investment in U.S. real property by Non-residents can be structured to minimize estate and gift taxes. The key is to structure the investment through a limited liability company, limited partnership or corporation so that…more
 /  Business Organizations, Real Estate - Commercial, Real Estate - Residential, Taxation, Wills, Trusts, & Estate Planning

Mental Impairment as a Defense to Civil Penalties

There are severe penalties under the Internal Revenue Code (IRC) and Bank Secrecy Act (BSA) for willful failure to file Information Returns. Examples of Information Return are Report of Foreign Bank Account (FBAR) required…more
 /  Business Organizations, Taxation

Banking Problems for a Whole Industry

About half of the States have legalized marijuana for either or both medical and recreational use. Despite being legal under various state laws, businesses operating in the marijuana industry continue to encounter federal…more
 /  Business Organizations, Conflict of Laws, Finance & Banking

Enforcement of Foreign Tax Claims

In many cases we have handled the taxpayers were dual nationals who have not only failed to adequately disclose and report foreign bank account and income to the IRS, but have also failed to report to the other country. This…more
 /  International Law & Trade, Taxation

Tax Reform and the Role of Lobbyists

Tax reform will certainly be an important agend item in the Trump Administration. The published reports are that the initial focus will be on corporate reform with the objective of reducing tax rates on corporations from 35% to…more
 /  Business Organizations, Elections & Politics, Taxation

Prosecution of Employers Who Hire Illegal Aliens

To manage the flow of illegal immigration the Trump Administration will have to do more that build a physical wall. It will need to enforce existing employ laws. According to the Center for Immigration Studies..…more
 /  Immigration Law, Labor & Employment Law

Defenses Payroll Tax Fraud

Prosecution for payroll tax fraud is a high priority for the IRS and Department of Justice. Payroll tax fraud occurs in several manners, including false worker classification as independent contractors, understatement of…more
 /  Business Organizations, Commercial Law & Contracts, Labor & Employment Law, Taxation

Warning to "Marijuana Investors" Consider Federal Enforcement

The Controlled Substances Act ("CSA") lists Marijuana (cannabis) as a Schedule 1 drug. That means "the drug or substance has no currently accepted medical use in treatment in the United States. Efforts to reclassify marijuana…more
 /  Conflict of Laws, Criminal Law, Elections & Politics, Finance & Banking, Real Estate - Commercial

What happens if you fail to report cash payments to the IRS?

If you operate a trade or business and receive $10,000 or more in cash for goods or services you must file an IRS From 8300 and report the payment within 15 days. The calculation of the $10,000 threshold includes lump sum and…more
 /  Business Organizations, Taxation

Selling Marijuana is still a Federal Crime, but income must be reported

The prevalence of state laws legalizing the sale of marijuana does nothing to change federal law. Marijuana remains a Schedule 1 drug under the Controlled Substances Act, (21 USC 801, et seq). The act of manufacturing,…more
 /  Business Organizations, Conflict of Laws, Taxation

Failure to Maintain Business Records Can Lead to Prosecution

A recent appellate court case out of New York (U.S. vs. Marinello) affirmed the conviction for tax evasion of a taxpayer for failing to maintain business records and timely file income tax returns. The facts of the case are as…more
 /  Business Organizations, Criminal Law, Taxation

Reasonable Cause: When can you rely on a tax professional to avoid penalties ?

When can a taxpayer rely on the advice of a tax professional is fundamental to establishing "reasonable cause" for failure to timely file tax returns. The U.S. Supreme Court stated the standard for what constitutes reasonable…more
 /  Taxation, Wills, Trusts, & Estate Planning

Banking Through Shell Companies Just Got Harder

For many U.S. and non-U.S. persons access to the U.S. banking system is key to preservation of the wealth or operation of their business. Anyone looking for banking security and liquidity will maintain an account in a U.S. bank,…more
 /  Finance & Banking, International Law & Trade

Offshore Enforcement Remains Top Priority of DOJ

Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivers remarks regarding the tax division's offshore tax enforcement efforts at the Panama Bankers Association Anti-Money-Laundering Conference…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Taxation
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