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

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

Streamline Certification Advice

Effective July 1, 2014 new Streamline Procedures for voluntary disclosures may provide some taxpayers the opportunity to pay a substantially reduced or no penalty FBAR penalty depending upon whether they are domestic or…more
| Finance & Banking, International Law & Trade, Taxation

Reporting Foreign Account Gifts

One of the areas of inquiry that is certain to receive increased attention by the IRS and Department of Justice (DOJ) is the claim that the funds in offshore accounts were the result of a “gift”. The proper documentation of…more
| Finance & Banking, International Law & Trade, Taxation, Wills, Trusts, & Estate Planning

False Foreign Gift Claims and Wire Fraud

A scheme that some dual national taxpayers have used involves claiming exemption from foreign jurisdiction taxation because they are U.S. taxpayers and then not reporting the offshore account or its income as required by U.S…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation, Wills, Trusts, & Estate Planning

Traps Within the new Streamline Offshore Account Disclosure Program

The new Streamlined Filing Compliance Procedures (the Streamline Procedures) go into effect July 1, 2014. Under the terms of the procedures some taxpayers will suffer no penalty for failure to timely file FBARs, (in the case of…more
| Finance & Banking, International Law & Trade, Taxation

Updated Roadmap To IRS’ 2014 Offshore Voluntary Disclosure Program For Taxpayers With Undisclosed Offshore Accounts

On June 18, 2014 the Internal Revenue Service (“IRS”) announced a modification to the 2012 Offshore Voluntary Disclosure Program (“OVDP”). The 2014 OVDP is a continuation of the 2012 program with modified terms. The voluntary…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation

IRS Offshore Enforcement Update

In a recent appearance before THE U.S. Conference for International Business the IRS Commissioner stated the following: “One of the most exciting aspects of our current times is to see governments working so…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation
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Areas of Practice
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  • Taxation
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