Sanford Millar – Law Offices of Sanford I. Millar

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

  • 310-556-3007
  • 310-556-3094

Should You Consider Making a Domestic Voluntary Disclosure?

Voluntary Disclosures take two forms, Offshore and Domestic. There has been a great deal of attention paid to Offshore Voluntary Disclosure Programs, but little attention has been paid to the Domestic program…more
| Commercial Law & Contracts, Taxation

When Do Non-U.S. Citizens Pay Income Tax And Report Foreign Financial Accounts?

In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes…more
| Finance & Banking, International Law & Trade, Taxation

The Death Of Hidden Offshore Accounts

The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The…more
| Finance & Banking, International Law & Trade, Taxation

Happy Holidays – There is a Budget Deal, Now Look Out

The just passed budget deal known as Consolidated and Further Continuing Appropriations Act, 2015 contains a reduction in funding for the IRS. The Bill provides a reduction in total IRS funding of $346 million less than last…more
| Elections & Politics, Finance & Banking, Taxation

Informal Surrender Of Green Card Doesn’t Work

The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax purposes…more
| Immigration Law, International Law & Trade, Taxation

Orwell’s 1984 30 Year Later

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax…more
| Finance & Banking, International Law & Trade, Taxation

U.S. Will Disclose Swiss Bank Information

The Department of Justice (DOJ) recently made demand of 106 Swiss banks for information and cooperation under the terms of proposed Non-prosecution agreements (NPA). Non-prosecution agreements were offered to Swiss banks in 2013…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Put Another Notch in the DOJ Gun

In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of…more
| Finance & Banking, International Law & Trade, Taxation

IRS Use of Customs Hold for International Taxpayers

In a recent Memorandum from the Treasury Inspector General Tax Administration (“TIGTA”) to the IRS TIGTA discussed one of the methods the IRS uses in its efforts to collect delinquent taxes and penalties, namely the Customs…more
| International Law & Trade, Taxation

FATCA Letters-What Should I Do Now?

As a result of the Foreign Account Tax Compliance Act, (FATCA), the latest estimates are that over 77,000 Foreign Financial Institutions (FFI’s) and over 80 foreign governments have entered into agreements to provide information…more
| Finance & Banking, International Law & Trade, Taxation

Offshore Voluntary Discloure; Is it too late

September 15, 2014 is an important for taxpayer who maintained accounts at any of 106 Swiss banks (participating banks) that are participating in the Department of Justice non-prosecution program. Here is why…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Streamline Procedure-What does non-willful mean?

In order to use the Streamline Procedures (domestic and non-resident) a U.S. taxpayer must certify that their failure to file a timely FBAR was non-willful. The term non-willful is essentially a “clinical” conclusion based upon…more
| Finance & Banking, International Law & Trade, Taxation

Don’t Stop Corporate Inversions

If you want to see specific stocks take a hit then stop corporate inversions. Corporate inversions are the relocation of a U.S. company’s corporate domicile, (its formal headquarters) to a lower tax jurisdiction. Inversions are…more
| Commercial Law & Contracts, Elections & Politics, International Law & Trade, Taxation

What Does a Fiduciary Do When Advised of an Offshore Account?

On June 18, 2014 the IRS announced changes to the Offshore Voluntary Disclosure Program (OVDP). The changes include the following..…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Forget About Hiding Money Offshore!

On July 21, 2014 the OECD released the full version of a new global standard for the exchange of financial information in tax matters “OECD\Standard for Automatic Exchange of Financial Account Information in Tax Matters”…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation
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Areas of Practice
  • Business Organizations
  • Taxation
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