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Sanford Millar – Law Offices of Sanford I. Millar

EB-5 Visas Applicant Need Tax Opinions

An EB-5 Visa is known as an “investor” visa. The following is an explanation of the EB-5 program..…more

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

Reasonable Cause Explained

Taxpayer’s often find themselves facing substantial penalties for failing to file or late payment of income estate or gift tax return. Some taxpayers face enormous penalties for failing to file a Report of Foreign Bank or…more

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

OVDP or 50% FBAR Willfulness Penalty; It is Your Choice

The Criminal Tax Division of the U.S. Dept of Justice (DOJ)is taking the position that when a taxpayer has “willfully” failed to file a Report of Foreign Bank or Financial Account, an FBAR, and has in addition filed false income…more

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

The 50% FBAR Penalty, Are you at Risk?

June 30 is the deadline for U.S. taxpayers, (including resident aliens) to timely report foreign financial accounts for the year ending 2012. The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has control…more

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

Son of FATCA – Swiss/U.K. Agree on Information Exchange

In what is clearly the first of many to come intergovernmental agreements similar to the Foreign Account Tax Compliance Acct (FATCA) adopted by the U.S. in 2010, the governments of Switzerland and the United Kingdom entered into…more

| Finance & Banking, International Law & Trade, Taxation

Why California Needs a New Voluntary Disclosure Program.

“Sometimes for taxpayers, who have serious tax non-compliance issues or may be facing international tax enforcement, the option of initiating a state voluntary disclosure contemporaneously with the making of a federal voluntary…more

| Finance & Banking, International Law & Trade, Taxation

Non-FBAR Penalites and Offshore Voluntary Disclosures

The following summarizes in explicit detail why taxpayers who have an unfilled Report of Foreign Financial or Bank Account (FBAR) must consider entering the Offshore Voluntary Disclosure Program (OVDP). Not only does the…more

| Finance & Banking, International Law & Trade, Taxation

FBAR Penalties and the Reasonable Cause Defense

Some taxpayer’s who think that they have properly relied on the advice of professionals and should therefore be able to avoid FBAR penalties need to consider what constitutes “reasonable cause”. First, the reasonable cause cases…more

| Finance & Banking, International Law & Trade, Taxation

Tax Traps Accompany EB-5 Visas

EB-5 Visas are sought after investment based pathways to a Green card. An EB-5 Visa is described in Wikipedia as follows..…more

| Finance & Banking, Immigration Law, Taxation

Must You Produce Records of Offshore Accounts?

A Petition to the U.S.Supreme Court may result in the Court deciding whether a taxpayer who has a previously unreported foreign financial account must produce records of the account in a criminal proceeding in spite of the…more

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

FBAR-The New Marriage Penalty

For those U.S. taxpayers who are married to non-residents there is a new form of marriage penalty if the spouses filed joint returns. To be eligible to file joint returns an election must be made with the first joint return in…more

| Administrative Law, Family Law, Finance & Banking, International Law &...

IRS Expanding Offshore Enforcement

Recently the Acting IRS Commissioner said: “While successful implementation of the Foreign Account Tax Compliance Act will assist the IRS in pursuing tax evaders, it is not the government’s sole answer to the long-term…more

| Administrative Law, Finance & Banking, International Law & Trade,...

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