Sanford Millar – Law Offices of Sanford I. Millar

Justice Department Focuing 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

Can Spys and Criminals Make Voluntary Disclosures?

A recent article about convicted spy Jonathan Pollard speculated about the effects on his parole if he had an unreported foreign financial account. The simple truth is that Mr. Pollard would be ineligible for the Offshore…more
| Criminal Law, Finance & Banking, Taxation

IRS-State Information Sharing Agreements

The IRS published a list of Information Exchange agreements it has with state agencies, a copy of which is available here IRS State Information Exchange Table.pdf The disclosure of this list may help taxpayer's and…more
| Taxation

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
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Areas of Practice
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  • Taxation
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