Sanford Millar – Law Offices of Sanford I. Millar

Marijuana and the Tax Apocalypse

As Californians evaluate the potential for legalization of Marijuana it is important to consider the current state of conflict between state and federal laws and regulations regarding the production, distribution and sale of…more
| Business Organizations, Conflict of Laws, Finance & Banking, Taxation

Bad News About Unfiled FBARs, Another Indictment

A recent indictment by the United States Attorney's office in California illustrates the inter-relationship between curency transfer restrictions, (such as those involving Iran), foreign financial account reporting (the FBAR…more
| Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Swiss Bank Settlements-What's Next for U.S. Taxpayer's?

The Department of Justice has released the signed Non-Prosecution Agreement NPA) with Swiss bank BSI SA. The Non-Prosecution Agreement is likely the precursor to enhanced enforcement efforts by the DOJ and IRS against those…more
| Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Warning, Offshore Accounts Holders May 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
| Civil Procedure, Criminal Law, Finance & Banking, International Law & Trade, Taxation

Cash Businesses Must Maintain Records

A recent Tax Court case (Kunkle v. C.I.R.) reiterates the need for cash businesses to maintain proper books and records. "Section 6662 imposes a 20% penalty upon the portion of any underpayment attributable to (among…more
| Business Organizations, Commercial Law & Contracts, Taxation

DOJ Warns Against Wrongful Use of Streamline Procedures

The U.S. Department of Justice is considering actions against taxpayers who wrongfully used the Streamlined Procedures to assert non-willful conduct. As quoted in Tax Notes Today..…more
| Commercial Law & Contracts, International Law & Trade, Taxation

How Not to Use Bitcoin

The use of Bitcoin has both legal and potentially illegal applications. Bitcoin is just a contemporary version of the Informal Value Transfer System, (“IVTS”) which in some countries is known as the Hawala. The IVTS has been…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Cash Based Business? Have Good Books and Records

What happens when a taxpayer operates a cash based business and lacks adequate books and records according to the IRS? The IRS can use any reasonable method to reconstruct the taxpayers income and expenses. (See, Estate of…more
| Business Organizations, Taxation

IRS Focus: Offshore Tax Evasion Tops Dirty Dozen List

The IRS issued two New Releases this week that restate its focus on offshore tax evasion. The first was January 29, 2015 which followed the First International Criminal Tax Symposium…more
| Commercial Law & Contracts, Criminal Law, International Law & Trade, Science, Computers, & Technology, Taxation

London Mayor Agrees to Pay IRS

According to Tax Notes Today (January 23, 2015) Boris Johnson the Mayor of London has settled tax claims of the IRS. The claim arose because Johnson who holds U.S and U.K. citizenship sold his residence at a gain and failed to…more
| International Law & Trade, Taxation

Should You Consider Making a Domestic Voluntary Disclosure?

Voluntary Disclosures take two forms, Offshore and Domestic. There has been a great deal of attention paid to Offshore Voluntary Disclosure Programs, but little attention has been paid to the Domestic program…more
| Commercial Law & Contracts, Taxation

When Do Non-U.S. Citizens Pay Income Tax And Report Foreign Financial Accounts?

In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes…more
| Finance & Banking, International Law & Trade, Taxation

The Death Of Hidden Offshore Accounts

The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The…more
| Finance & Banking, International Law & Trade, Taxation

Happy Holidays – There is a Budget Deal, Now Look Out

The just passed budget deal known as Consolidated and Further Continuing Appropriations Act, 2015 contains a reduction in funding for the IRS. The Bill provides a reduction in total IRS funding of $346 million less than last…more
| Elections & Politics, Finance & Banking, Taxation

Informal Surrender Of Green Card Doesn’t Work

The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax purposes…more
| Immigration Law, International Law & Trade, Taxation
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Contact

1900 Avenue of the Stars 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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