Is Age A Defense to Failure to File Returns?

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, July 24, 2016

Two  recent cases illustrate why age alone is no defense to failure to file returns criminal and civil penalties.  The first case is a Tax Court Case in which the the taxpayer was assessed late iflingand late payment penalties.  The taxpyaer argued that his age and coplexity of the tax code were the reasons he … Continue reading Is Age A Defense to Failure to File Returns?

Streamline Procedure Risks: Are you really Non-willful?

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, July 10, 2016

According to reports in Tax Analysts there have been 54, 000 Offshore Voluntary Disclosure  (OVDP) participants 30,000 Streamline Procedure filings.  The Streamline Procedure filings are now the subject of intense Department of Justice (DOJ) and IRS review.  The DOJ and IRS ar looking for taxpayers who made improper use of the Streamline Procedures. There are … Continue reading Streamline Procedure Risks: Are you really Non-willful?

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

By Sanford Millar of MillarLaw A Professional Corporation On Monday, July 4, 2016

Recently, The Harvard Law School Forum on Croporate Governance and Finance published a note titled “The Legal Consequence of Brexit, authored by Simon Witty.  We have restated the transactional tax commentary here.  We have added our thoughts on the tax reporting, “information exchange agreements” and federal tax reporting requirements under the heading Compliance. “Tax The … Continue reading What are the Tax Consequences of BREXIT for U.S. Taxpayers?