DOJ WarnsAgainst Wrongful Use of Streamline Procedures

By of MillarLaw A Professional Corporation On Sunday, March 8, 2015

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: “Speaking at the Federal Bar Association Section on Taxation annual tax law conference in Washington, Caroline Ciraolo, acting assistant attorney general in the Tax Division, said, “We are taking … Continue reading DOJ WarnsAgainst Wrongful Use of Streamline Procedures

How Not to Use Bitcoin

By of MillarLaw A Professional Corporation On Sunday, February 22, 2015

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 used for international money transfers according to the Financial Crimes Enforcement Network (FinCen) for the following reasons: “IVTS-type … Continue reading How Not to Use Bitcoin

Cash Based Business? Have Good Books and Records

By of MillarLaw A Professional Corporation On Saturday, February 7, 2015

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 Rodrigo F. Fenta, et al. v. Commissioner, TC Summary Opinion 2015-4 ) In the opinion the court states … Continue reading Cash Based Business? Have Good Books and Records

London Mayor Agrees to Pay IRS

By of MillarLaw A Professional Corporation On Sunday, January 25, 2015

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 report the gain for U.S. income tax purposes. Johnson, who apparently travels to the … Continue reading London Mayor Agrees to Pay IRS

Should You Consider Making a Domestic Voluntary Disclosure?

By of MillarLaw A Professional Corporation On Sunday, January 18, 2015

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. The Internal Revenue Manual provides U.S. taxpayers with the opportunity to come forward and possibly avoid prosecution if the following criteria are met: … Continue reading Should You Consider Making a Domestic Voluntary Disclosure?

When do non-U.S. citizens pay income tax and report foreign financial accounts?

By of MillarLaw A Professional Corporation On Sunday, January 11, 2015

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. The report states as follows: “Non-citizens who may be subject to U.S. income taxes include legal permanent residents who are authorized to live and work in … Continue reading When do non-U.S. citizens pay income tax and report foreign financial accounts?

The death of hidden offshore accounts

By of MillarLaw A Professional Corporation On Sunday, January 4, 2015

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 link below is to a video summary of the predicted consequences of the new agreement. http://www.dw.de/interview-with-achim-pross-of-the-oecd/av-18029709 What … Continue reading The death of hidden offshore accounts

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

By of MillarLaw A Professional Corporation On Sunday, December 14, 2014

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 fiscal year. “Internal Revenue Service (IRS): Failing to collect what taxpayers owe leaves the federal budget short about … Continue reading Happy Holidays – There is a Budget Deal, Now Look Out

Informal surrender of Green Card doesn’t work

By of MillarLaw A Professional Corporation On Sunday, November 9, 2014

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. As stated in Checkpoint, ” The Tax Court held that because the taxpayer did not formally abandon his lawful permanent resident “LPR” … Continue reading Informal surrender of Green Card doesn’t work

Orwell’s 1984 30 Year Later

By of MillarLaw A Professional Corporation On Sunday, November 2, 2014

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax Transparency convened by the OECD/G20 51 countries signed on to the automatic exchange … Continue reading Orwell’s 1984 30 Year Later