Sanford Millar – Law Offices of Sanford I. Millar

California Steps Up Criminal Tax Enforcement

California has a multi-agency task force known as the Revenue Recovery and Enforcement Team that was established to attack criminal tax evasion. The stated goals of the team are: (a) According to the State Board of…more
| Business Organizations, Taxation

Who Are The Likely Targets of the Offshore Law Firm Date Leak?

The reports of a massive leak of confidential client information from files of the Mossack Fonseca & Co., law firm could have far ranging effects from intelligence, law enforcement and commercial perspectives. The interesting…more
| Business Organizations, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Taxation

Your IRA is NOT a Bank. Borrowing From Your IRA May Have Serious Tax Consequences

The U.S. Tax Court issued a Decision in Thiessen v. Commissioner that may have effect on many small business owners who have used their IRA's for financing purposes. In Thiessen, the taxpayers were found to have engaged in a…more
| Business Organizations, Taxation

When Offshore Asset Protection Fails

What happens when The IRS attacks your offshore asset protection plan? The simple answer is you may face a variety of civil and criminal investigations and penalties. What constitutes an offshore asset protection plan?…more
| Business Organizations, Taxation

Reasonable Cause and Record Reconstruction

Individuals suffering from mental illness or the effects of substance abuse may have a "reasonable cause" for penalty relief. Example, an individual who is suffering from chronic drug dependency who may have been in and out of…more
| Taxation

Is Mental Impairment a Basis to Claim "Non-willful" Behavior?

The Tax Crimes Handbook of the Office of Chief Counsel, Criminal Tax Division of the Internal Revenue Service defines "Willfulness” as follows..…more
| Taxation

What is the likely effect of Justice Scalia's death on Tax cases pending in the USSCT

Justice Scalia is known as an "originalist" in interpreting the Constitution. An "originalist" is someone who looks to the language of the Constitution to find authority for an interpretation being proposed and who finding none…more
| Business Organizations, Securities Law, Taxation

IRS 80- Swiss Banks 0

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or…more
| Criminal Law, Finance & Banking, Taxation

Caution: Not All Iran Sanctions Were Terminated

U.S. persons, including permanent resident aliens and dual nationals should note that the Lifting of U.S. Sanctions on Iran under the Joint Comprehensive Plan of Action does not lift all sanctions…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

What's Next in Foreign Account Enforcement?

The Department of Justice and the IRS are now mining the wealth of data obtained through settlements (Non-Prosecution Agreements) with almost 100 Swiss banks. The search through the data is methodical…more
| Finance & Banking, International Law & Trade

Tax Plans of the Presidential Candidates

Tax Proposals of the Presidential Candidates. Happy Planning The Tax Policy Center (TPC) has done an analysis of the tax plans of the major U.S. presidential candidates…more
| Elections & Politics, Taxation

What's Your Audit Risk? It Depends!

Taxpayers who are considering one of the Streamline Procedures (Non-resident or Resident) have been advised by the IRS that their returns are subject to the regular audit selection process even though they must identify their…more
| Finance & Banking, International Law & Trade, Taxation

Snowden is Only Part of the Disclosure Story

Edward Snowden may have brought attention to telephonic (voice and data) intelligence agencies both U.S and others, but I speculate that his revelations most likely have not changed the bulk of non-criminal or terrorist…more
| Finance & Banking, International Law & Trade, Securities Law

Who Must Report Foreign Corporations

The IRS recently published an internal guidance on who must report interests in foreign corporations and the penalties for non-compliance. Who must report..…more
| Business Organizations, Commercial Law & Contracts, Taxation

Offshore Accounts Still Focus of IRS Enforcement

The following Notice from the IRS reiterates the enforcement focus on offshore accounts. Anyone with an unreported offshore account needs to consult counsel and discuss, their compliance options under the "attorney-client…more
| Finance & Banking, International Law & Trade, Taxation
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Suite 650
Greater Los Angeles Area, California 90067, United States

  • 310-556-3007
  • 310-556-3094

Areas of Practice
  • Business Organizations
  • Taxation
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