Is Mental Impairment a Basis to Claim “Non-willful” Behaivor?

By Sanford Millar of MillarLaw A Professional Corporation On Monday, February 22, 2016

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 legal duty.” Cheek v. United States, 498 U.S. 192, 200-01 (1991); United States v. Pomponio, 429 U.S. 10, 12 (1976); … Continue reading Is Mental Impairment a Basis to Claim “Non-willful” Behaivor?

What is the likely effect of Justice Scalia’s death on Tax cases pending in the USSCT

By Sanford Millar of MillarLaw A Professional Corporation On Monday, February 15, 2016

Justice Scalia is known as an “originalist” in interpreting the Constitution.  An “originalist” is someone who looks to the language of the Constitution to find authority for an interpretation being proposed and who finding none would deny the requested relief.  An example of how his “originalist” approach was used in tax cases is found in … Continue reading What is the likely effect of Justice Scalia’s death on Tax cases pending in the USSCT

IRS 80- Swiss Banks 0

By Sanford Millar of MillarLaw A Professional Corporation On Monday, February 1, 2016

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or assisted U.S. taxpayers in offshore tax evasion. In addition to disclosure and cooperation with investigations each of the banks paid substantial penalties. … Continue reading IRS 80- Swiss Banks 0