Warning!!! Pre-paid State and Local Taxes are NOT DEDUCTIBLE in 2017 If they are due in 2018!

By of MillarLaw A Professional Corporation On Sunday, December 17, 2017

  Assuming that the Tax Cuts and Jobs Act (“TCJA”) passes both Houses of Congress and is signed by the president, there will be monumental changes in the Internal Revenue Code on the individual and corporate tax levels. One example is the limitation on the part of individuals to deduct state and local taxes (“SALT”). … Continue reading Warning!!! Pre-paid State and Local Taxes are NOT DEDUCTIBLE in 2017 If they are due in 2018!

US prosecutors seek tenfold increase in offshore evasion sentences

By of MillarLaw A Professional Corporation On Sunday,

A conviction for failure to report offshore financial account now carries a far greater risk of a lengthy prison term according to Mark Daly, senior litigation counsel at the U.S. Department of Justice. US prosecutors seek tenfold increase in offshore evasion sentences The Journal STEP is reporting that the US DoJ will, in future, press … Continue reading US prosecutors seek tenfold increase in offshore evasion sentences

Coinbase to turn over information to IRS. What does it mean for the bitcoin day trader?

By of MillarLaw A Professional Corporation On Saturday, December 2, 2017

By Ani Galyan Esq, CPA, LLM On December 6, 2016 the Department of Justice (DOJ) served a “John Doe” summons to Coinbase, a San Francisco based exchange of cryptocurrency, to produce records of accounts held by U.S. taxpayers for the period of 2013 through 2015. In IRS Notice 2014-21, the IRS took the position that … Continue reading Coinbase to turn over information to IRS. What does it mean for the bitcoin day trader?

What would happen to the value of cryptocurrencies if Exchanges had to Issue a Form 1099 on an annual basis?

By of MillarLaw A Professional Corporation On Sunday, November 26, 2017

The IRS issued a John DOE Summons for records of U.S. account holders of Coinbase, Inc. (“Coinbase”)a cryptocurrency exchange based in San Francisco, California. Coinbase objected to production of the records and a Summons Enforcement case was brought in the United State District Court, Northern District of California. A John DOE Summons is authorized under … Continue reading What would happen to the value of cryptocurrencies if Exchanges had to Issue a Form 1099 on an annual basis?

WHAT IF YOU ARE INELIGIBLE FOR THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM? Attorney Proffers versus Quiet Disclosures

By of MillarLaw A Professional Corporation On Sunday, November 19, 2017

Since the beginning of the current Offshore Voluntary Disclosure Programs (OVDP) in 2009 tens of thousands of U.S. taxpayers have come forward to report previously undisclosed foreign financial accounts. The addition of the Delinquent filing Program and Streamline Procedures (the “Other Programs”) have added to those numbers and resulted in billions of dollars in tax, … Continue reading WHAT IF YOU ARE INELIGIBLE FOR THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM? Attorney Proffers versus Quiet Disclosures

A valid marriage is required to file a Joint Return. What is a valid marriage?

By of MillarLaw A Professional Corporation On Sunday,

Assuming that you have a valid marriage for federal income tax purposes, as defined in “Section 301.7701-18(b)(1) of the Procedure and Administration Regulations that a marriage of two individuals is recognized for federal tax purposes if the marriage is recognized by the state, possession, or territory of the United States in which the marriage is … Continue reading A valid marriage is required to file a Joint Return. What is a valid marriage?

Avoiding the Automatic $10,000 penalty for late filing an international information return

By of MillarLaw A Professional Corporation On Sunday,

Taxpayers who fail to timely file international information returns, such as Form 3520, Annual Return of a Controlled Foreign Corporation are subject to an automatic assessment of $10,000 per return per year up to a maximum of $60,000 per return per year if the simply file the return late. However for those taxpayers who use … Continue reading Avoiding the Automatic $10,000 penalty for late filing an international information return

Will Your Offshore Bank or Cryptocurrency Exchange Turn You In to the IRS?

By of MillarLaw A Professional Corporation On Sunday,

Well the results of the Foreign Account tax Compliance Act (“FATCA”) are coming in and the IRS will be stepping up audit of “holder” of unreported account. The exam targets will be U.S. taxpayers who own or control foreign account and who have not properly disclosed those foreign financial accounts. The taxpayers will likely be … Continue reading Will Your Offshore Bank or Cryptocurrency Exchange Turn You In to the IRS?

Avoiding the “Automatic” $10,000 penalty for late filing of International Information Returns

By of MillarLaw A Professional Corporation On Sunday, November 12, 2017

Taxpayers who fail to timely file international information returns, such as Form 3520, Annual Return of a Controlled Foreign Corporation are subject to an automatic assessment of $10,000 per return per year up to a maximum of $60,000 per return per year if the simply file the return late. However for those taxpayers who use … Continue reading Avoiding the “Automatic” $10,000 penalty for late filing of International Information Returns

Offshore Assets May Be Subject to Enforced Collection by the IRS

By of MillarLaw A Professional Corporation On Friday, November 10, 2017

The fact that you may have assets offshore does not mean that they are immune from seizure by the IRS. A recent case illustrates how the IRS can enforce collection outside the United States. In Dewees the taxpayer was a dual national living in Canada with no U.S. assets. The taxpayer first entered the Offshore … Continue reading Offshore Assets May Be Subject to Enforced Collection by the IRS