Sanford Millar – Law Offices of Sanford I. Millar

Is Age A Defense to Failure to File Returns?

Two recent cases illustrate why age alone is no defense to failure to file returns criminal and civil penalties. The first case is a Tax Court Case in which the taxpayer was assessed late filing and late payment penalties. The…more
| Taxation

Streamline Procedure Risks: Are you really Non-willful?

According to reports in Tax Analysts there have been 54, 000 Offshore Voluntary Disclosure (OVDP) participants 30,000 Streamline Procedure filings. The Streamline Procedure filings are now the subject of intense Department of…more
| Taxation

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have…more
| Business Organizations, Elections & Politics, International Law & Trade, Taxation

Is Mental Incapacity a Defense to Tax Penalties and FBAR Penalties?

The Tax Crimes Handbook of the Office of Chief Counsel, Criminal Tax Division of the Internal Revenue Service defines "Willfulness” as follows: "[a] Willfulness is defined as the "voluntary, intentional violation of a known…more
| Taxation

If Time is Money Should Business People Use Private Jets?

The long check-in lines, irritating fees, complex routing and lack of confidentiality in conversations has motivated many businesses to use private jets for their executives. One of the issues in acquiring, or chartering a…more
| Business Organizations, Taxation, Transportation

Foreign Bank Account Reports Due June 30

U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30. Taxpayers with unfiled FBARs…more
| Business Organizations, Finance & Banking, Taxation

You Skipped OVDP, now the IRS has initiated an Audit

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act…more
| Business Organizations, Finance & Banking, International Law & Trade, Taxation

Panama Papers To Be Released May 9, 2016. Why Does It Matter?

The International Consortium of Investigative Journalists (ICIJ) will release perhaps the largest database of private offshore companies and their ultimate owner ever made public. According to the ICIJ..…more
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California Steps Up Criminal Tax Enforcement

California has a multi-agency task force known as the Revenue Recovery and Enforcement Team that was established to attack criminal tax evasion. The stated goals of the team are: (a) According to the State Board of…more
| Business Organizations, Taxation

Who Are The Likely Targets of the Offshore Law Firm Date Leak?

The reports of a massive leak of confidential client information from files of the Mossack Fonseca & Co., law firm could have far ranging effects from intelligence, law enforcement and commercial perspectives. The interesting…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Taxation

Your IRA is NOT a Bank. Borrowing From Your IRA May Have Serious Tax Consequences

The U.S. Tax Court issued a Decision in Thiessen v. Commissioner that may have effect on many small business owners who have used their IRA's for financing purposes. In Thiessen, the taxpayers were found to have engaged in a…more
| Business Organizations, Taxation

When Offshore Asset Protection Fails

What happens when The IRS attacks your offshore asset protection plan? The simple answer is you may face a variety of civil and criminal investigations and penalties. What constitutes an offshore asset protection plan?…more
| Business Organizations, Taxation

Reasonable Cause and Record Reconstruction

Individuals suffering from mental illness or the effects of substance abuse may have a "reasonable cause" for penalty relief. Example, an individual who is suffering from chronic drug dependency who may have been in and out of…more
| Taxation

Is Mental Impairment a Basis to Claim "Non-willful" Behavior?

The Tax Crimes Handbook of the Office of Chief Counsel, Criminal Tax Division of the Internal Revenue Service defines "Willfulness” as follows..…more
| Taxation

What is the likely effect of Justice Scalia's death on Tax cases pending in the USSCT

Justice Scalia is known as an "originalist" in interpreting the Constitution. An "originalist" is someone who looks to the language of the Constitution to find authority for an interpretation being proposed and who finding none…more
| Business Organizations, Securities Law, Taxation
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  • 310-556-3007
  • 310-556-3094

Areas of Practice
  • Business Organizations
  • Taxation
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