How Does the IRS Determine if Conduct is “Willful” or “Non-Willful”?

By Ani Galyan of MillarLaw A Professional Corporation On Monday, June 22, 2015

WILLFUL V. NON-WILLFUL CHECKLIST INTRODUCTION This Article is a guide for practitioners and taxpayers in deciding whether to apply for the streamline procedures of the IRS’s Offshore Voluntary Disclosure Program (“OVDP”). The streamline procedures require a certification of non-willfulness from the taxpayer. Non-willful conduct is defined as conduct that is due to negligence, inadvertence, or … Continue reading How Does the IRS Determine if Conduct is “Willful” or “Non-Willful”?

Delinquent FBAR Reporting and How to Come Forward? Fact and Choice of Method Really Matter!!!

By Sanford Millar of MillarLaw A Professional Corporation On Monday, June 15, 2015

FBARS for 2014 are Due and MUST BE FILED by June 30, 2015 There are three approaches to coming forward and filing delinquent FBAR’s (Report of Foreign Financial Account). They are: 1. The Delinquent Filing Procedure 2. The Streamline Domestic Procedure and Streamline Non-resident Procedure 3. The Offshore Voluntary Disclosure Program The choice of which … Continue reading Delinquent FBAR Reporting and How to Come Forward? Fact and Choice of Method Really Matter!!!

Domestic Voluntry Discloure as an Alternative to Indictment

By Sanford Millar of MillarLaw A Professional Corporation On Monday, June 8, 2015

The United States Attorney for the Southern District of New York announced that the “owner and operator of DNS Construction Corporation, was sentenced today in Manhattan federal court to a term of five years of probation and $883,730.52 in restitution for committing two counts of tax fraud by failing to pay over $800,000 in income … Continue reading Domestic Voluntry Discloure as an Alternative to Indictment

U.S. Department of Justice States its Tax Enforcement Priorities

By of MillarLaw A Professional Corporation On Monday, June 1, 2015

In her recent testimony before Congress Caroline Ciraolo Acting Assistant Attorney General stated the enforcement priorities for the Tax Division. Among the the four areas of focus is Offshore Tax Evasion. “combating the use of foreign bank accounts to evade U.S. taxes has been a longstanding enforcement priority for the Tax Division. Since 2009, when … Continue reading U.S. Department of Justice States its Tax Enforcement Priorities