Sanford Millar – Law Offices of Sanford I. Millar

Offshore Disclosure: What Needs To Be Disclosed? A Checklist

The following is a list of questions that should lead to the discovery of offshore assets, whether properly reported or not. If you answer yes to any of these questions, then you may have filing obligations and should seek…more

| Finance & Banking, International Law & Trade, Taxation, Wills, Trusts, &...

Are you an innocent spouse for FBAR purposes?

The U.S. Tax Court (Tax Court) has restated the basic principles for a person to obtain “innocent spouse” relief from tax assessments. The criteria are as follows..…more

| International Law & Trade, Taxation

Update: U.S. International Tax Enforcement Efforts

On February 25, 2014 the U.S. Senate Permanent Subcommittee on Investigations, issued its report on its investigation into offshore tax evasion and the participation of Swiss Banks. Specific recommendations were made, among…more

| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Who Is Next, Now That Swiss Banks Will Turn Over Account Data?

What do you do if your offshore account is at one of 14 Swiss banks currently under criminal investigation? What do you do if your offshore account is at one of the 106 Swiss banks that have entered into non-prosecution…more

| Finance & Banking, International Law & Trade, Taxation

Must BitCoin Users file Reports of Foreign Bank Accounts (FBARs)?

A great deal of attention has been paid to BitCoin by the media, including the financial press. Among the reasons offered for using BitCoin is privacy and anonymity. However, a subtext in the rationale is that because of the…more

| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Unreported Foreign Gifts and Divorce

In a recently released Chief Counsel Advisory (CCA) the IRS addressed the statute of limitations on assessment of penalties for failure to report gifts from foreign persons. The CCA states..…more

| Civil Procedure, Family Law, International Law & Trade, Taxation

Is Time Running Out for the Offshore Voluntary Disclosure Program?

The deadline imposed by the Department of Justice (DOJ) for approximately 300 Swiss banks to come forward and request non-prosecution agreements expires December 16, 2013. In order to be eligible for a non-prosecution agreement…more

| Finance & Banking, International Law & Trade, Taxation

Divorce: Finding Offshore Assets

One of the more important issues in a divorce proceeding is identifying and dividing community and separate property. The task of asset identification and location may have been made both easier and more complex at the same time…more

| Civil Procedure, Finance & Banking, Family Law, International Law &...

Justice Dept. Warning to Swiss Banks Means Trouble for U.S. Taxpayers

On November 5, 2013 the Department of Justice issued a letter of explanation to Swiss banks. A portion of the warning is restated: “Each eligible Swiss bank should carefully weigh the benefits of coming forward, and the…more

| Criminal Law, Finance & Banking, International Law & Trade, Taxation

More Swiss Banks Will Disclose/Cooperate with Offshore Tax Investigations

The U.S. Department of Justice (DOJ) offer of non-prosecution agreements to certain Swiss banks expires December 31, 2013. Swiss banks who know or suspect that they have violated U.S. law, but who are not currently the subject…more

| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Offshore Accounts Holders Have No Fifth Amendment Protections

In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the “required records doctrine” to compel taxpayer’s to produce what may be incriminating evidence of ownership or control of…more

| Constitutional Law, Criminal Law, Finance & Banking, International Law &...

This profile may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any correspondence with this profile holder does not constitute a client/attorney relationship. Neither the content on this profile nor transmissions between you and the profile holder through this profile are intended to provide legal or other advice or to create an attorney-client relationship.