Sanford Millar – Law Offices of Sanford I. Millar

IRS 80- Swiss Banks 0

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or…more
| Criminal Law, Finance & Banking, Taxation

Caution: Not All Iran Sanctions Were Terminated

U.S. persons, including permanent resident aliens and dual nationals should note that the Lifting of U.S. Sanctions on Iran under the Joint Comprehensive Plan of Action does not lift all sanctions…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

What's Next in Foreign Account Enforcement?

The Department of Justice and the IRS are now mining the wealth of data obtained through settlements (Non-Prosecution Agreements) with almost 100 Swiss banks. The search through the data is methodical…more
| Finance & Banking, International Law & Trade

Tax Plans of the Presidential Candidates

Tax Proposals of the Presidential Candidates. Happy Planning The Tax Policy Center (TPC) has done an analysis of the tax plans of the major U.S. presidential candidates…more
| Elections & Politics, Taxation

What's Your Audit Risk? It Depends!

Taxpayers who are considering one of the Streamline Procedures (Non-resident or Resident) have been advised by the IRS that their returns are subject to the regular audit selection process even though they must identify their…more
| Finance & Banking, International Law & Trade, Taxation

Snowden is Only Part of the Disclosure Story

Edward Snowden may have brought attention to telephonic (voice and data) intelligence agencies both U.S and others, but I speculate that his revelations most likely have not changed the bulk of non-criminal or terrorist…more
| Finance & Banking, International Law & Trade, Securities Law

Who Must Report Foreign Corporations

The IRS recently published an internal guidance on who must report interests in foreign corporations and the penalties for non-compliance. Who must report..…more
| Business Organizations, Commercial Law & Contracts, Taxation

Offshore Accounts Still Focus of IRS Enforcement

The following Notice from the IRS reiterates the enforcement focus on offshore accounts. Anyone with an unreported offshore account needs to consult counsel and discuss, their compliance options under the "attorney-client…more
| Finance & Banking, International Law & Trade, Taxation

Justice Department Focusing on Offshore Account

At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated..…more
| Finance & Banking, Taxation

It's Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade

Bad Bad, Bad Penalty, Bad OVDP Policy

There are now 50 foreign financial institutions on the IRS list of "bad banks" The list is published at the following link..…more
| Commercial Law & Contracts, Finance & Banking, Taxation

Giving Up U.S. Citizenship - Estate and Gift Tax Traps

It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to…more
| Immigration Law, Taxation, Wills, Trusts, & Estate Planning

Check Cashing, Tax Evasion, Structuring and Asset Forfeiture; The Making of a Bad Day

The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are deposited into the business bank…more
| Criminal Law, Finance & Banking, Taxation

Cash Payments to Workers; Convenience or Crime?

A common technique used to pay immigrants who are ineligible to lawfully work and to pay lawful workers "offbook" in order to reduce reported payroll for workers compensation and other purposes is to pay workers wholly or…more
| Immigration Law, Labor & Employment Law, Taxation

Cash Businesses, Poor Records and Obstruction Charges, Ouch!

Cash business operators are often prone to under report income or overstate deductions when filing tax returns. The effect of engaging in such conduct can be criminal charges, including tax evasion, money laundering and…more
| Commercial Law & Contracts, 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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