Sanford Millar – Law Offices of Sanford I. Millar

Failure to Maintain Business Records Can Lead to Prosecution

A recent appellate court case out of New York (U.S. vs. Marinello) affirmed the conviction for tax evasion of a taxpayer for failing to maintain business records and timely file income tax returns. The facts of the case are as…more
| Business Organizations, Criminal Law, Taxation

Reasonable Cause: When can you rely on a tax professional to avoid penalties ?

When can a taxpayer rely on the advice of a tax professional is fundamental to establishing "reasonable cause" for failure to timely file tax returns. The U.S. Supreme Court stated the standard for what constitutes reasonable…more
| Taxation, Wills, Trusts, & Estate Planning

Banking Through Shell Companies Just Got Harder

For many U.S. and non-U.S. persons access to the U.S. banking system is key to preservation of the wealth or operation of their business. Anyone looking for banking security and liquidity will maintain an account in a U.S. bank,…more
| Finance & Banking, International Law & Trade

Offshore Enforcement Remains Top Priority of DOJ

Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivers remarks regarding the tax division's offshore tax enforcement efforts at the Panama Bankers Association Anti-Money-Laundering Conference…more
| Business Organizations, Finance & Banking, International Law & Trade, Taxation

When the Internal Revenue Code and the FAA Regulations Collide - What Results?

The Federal Aviation Administration (FAA) categorizes aircraft owners and operators into different categories. In general, the FAA grants an owner of an aircraft who operates the aircraft for personal use and enjoyment a…more
| Business Organizations, Commercial Law & Contracts, Taxation, Transportation

Use of Shell Companies To Shield Identity Further Limited

On July 27, 2016 the Financial Crimes Enforcement Network, (FinCEN) of the Department of the Treasury issued expanded Geographic Targeting Orders (GTO) that will..…more
| Business Organizations, Finance & Banking, Real Estate - Commercial, Real Estate - Residential, Taxation

Is Age A Defense to Failure to File Returns?

Two recent cases illustrate why age alone is no defense to failure to file returns criminal and civil penalties. The first case is a Tax Court Case in which the taxpayer was assessed late filing and late payment penalties. The…more
| Taxation

Streamline Procedure Risks: Are you really Non-willful?

According to reports in Tax Analysts there have been 54, 000 Offshore Voluntary Disclosure (OVDP) participants 30,000 Streamline Procedure filings. The Streamline Procedure filings are now the subject of intense Department of…more
| Taxation

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have…more
| Business Organizations, Elections & Politics, International Law & Trade, Taxation

Is Mental Incapacity a Defense to Tax Penalties and FBAR Penalties?

The Tax Crimes Handbook of the Office of Chief Counsel, Criminal Tax Division of the Internal Revenue Service defines "Willfulness” as follows: "[a] Willfulness is defined as the "voluntary, intentional violation of a known…more
| Taxation

If Time is Money Should Business People Use Private Jets?

The long check-in lines, irritating fees, complex routing and lack of confidentiality in conversations has motivated many businesses to use private jets for their executives. One of the issues in acquiring, or chartering a…more
| Business Organizations, Taxation, Transportation

Foreign Bank Account Reports Due June 30

U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30. Taxpayers with unfiled FBARs…more
| Business Organizations, Finance & Banking, Taxation

You Skipped OVDP, now the IRS has initiated an Audit

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act…more
| Business Organizations, Finance & Banking, International Law & Trade, Taxation

Panama Papers To Be Released May 9, 2016. Why Does It Matter?

The International Consortium of Investigative Journalists (ICIJ) will release perhaps the largest database of private offshore companies and their ultimate owner ever made public. According to the ICIJ..…more

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
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Greater Los Angeles Area, California 90067, United States

  • 310-556-3007
  • 310-556-3094

Areas of Practice
  • Business Organizations
  • Taxation
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