Month: April 2015
Bad News About Unfiled FBARs, Another Indictment
By Sanford Millar of MillarLaw A Professional Corporation On Friday, April 24, 2015
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 requirement) and the failure to report taxable income (filing of a false tax return ). In United States of America vs. Ali Amin the government alleged … Continue reading Bad News About Unfiled FBARs, Another Indictment
Swiss Bank Settlements-What’s Next for U.S. Taxpayer’s?
By Sanford Millar of MillarLaw A Professional Corporation On Monday, April 20, 2015
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 taxpayers who have not yet come forward and disclosed previously unreported offshore accounts. The DOJ has publicly stated that it will … Continue reading Swiss Bank Settlements-What’s Next for U.S. Taxpayer’s?
Cash Businesses Must Maintain Records
By Sanford Millar of MillarLaw A Professional Corporation On Thursday, April 16, 2015
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 other things) negligence or disregard of rules or Regulations. The term “negligence” includes any failure to make a reasonable attempt … Continue reading Cash Businesses Must Maintain Records
Warning, Offshore Accounts Holders May Have No Fifth Amendment Protections
By Sanford Millar of MillarLaw A Professional Corporation On Monday, April 13, 2015
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 foreign financial accounts. The DoJ process involves the issuance of a Grand Jury subpoena for records and then compelled testimony. … Continue reading Warning, Offshore Accounts Holders May Have No Fifth Amendment Protections
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