A “Perry Mason” Moment
By of MillarLaw A Professional Corporation On Friday, January 19, 2018
Perry Mason was a television dram about a criminal defense lawyer who somehow managed to get his clients acquitted through clever cross examination of the real criminal. His techniques often managed to get the witness to confess “It was me, I did it” Just recently I had a Perry Mason moment but it occurred after … Continue reading A “Perry Mason” Moment
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!
DOJ WarnsAgainst Wrongful Use of Streamline Procedures
By of MillarLaw A Professional Corporation On Sunday, March 8, 2015
The U.S. Department of Justice is considering actions against taxpayers who wrongfully used the Streamlined Procedures to assert non-willful conduct. As quoted in Tax Notes Today: “Speaking at the Federal Bar Association Section on Taxation annual tax law conference in Washington, Caroline Ciraolo, acting assistant attorney general in the Tax Division, said, “We are taking … Continue reading DOJ WarnsAgainst Wrongful Use of Streamline Procedures
How Not to Use Bitcoin
By of MillarLaw A Professional Corporation On Sunday, February 22, 2015
The use of Bitcoin has both legal and potentially illegal applications. Bitcoin is just a contemporary version of the Informal Value Transfer System, (“IVTS”) which in some countries is known as the Hawala. The IVTS has been used for international money transfers according to the Financial Crimes Enforcement Network (FinCen) for the following reasons: “IVTS-type … Continue reading How Not to Use Bitcoin
Cash Based Business? Have Good Books and Records
By of MillarLaw A Professional Corporation On Saturday, February 7, 2015
What happens when a taxpayer operates a cash based business and lacks adequate books and records according to the IRS? The IRS can use any reasonable method to reconstruct the taxpayers income and expenses. (See, Estate of Rodrigo F. Fenta, et al. v. Commissioner, TC Summary Opinion 2015-4 ) In the opinion the court states … Continue reading Cash Based Business? Have Good Books and Records
London Mayor Agrees to Pay IRS
By of MillarLaw A Professional Corporation On Sunday, January 25, 2015
According to Tax Notes Today (January 23, 2015) Boris Johnson the Mayor of London has settled tax claims of the IRS. The claim arose because Johnson who holds U.S and U.K. citizenship sold his residence at a gain and failed to report the gain for U.S. income tax purposes. Johnson, who apparently travels to the … Continue reading London Mayor Agrees to Pay IRS
Should You Consider Making a Domestic Voluntary Disclosure?
By of MillarLaw A Professional Corporation On Sunday, January 18, 2015
Voluntary Disclosures take two forms, Offshore and Domestic. There has been a great deal of attention paid to Offshore Voluntary Disclosure Programs, but little attention has been paid to the Domestic program. The Internal Revenue Manual provides U.S. taxpayers with the opportunity to come forward and possibly avoid prosecution if the following criteria are met: … Continue reading Should You Consider Making a Domestic Voluntary Disclosure?
When do non-U.S. citizens pay income tax and report foreign financial accounts?
By of MillarLaw A Professional Corporation On Sunday, January 11, 2015
In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes. The report states as follows: “Non-citizens who may be subject to U.S. income taxes include legal permanent residents who are authorized to live and work in … Continue reading When do non-U.S. citizens pay income tax and report foreign financial accounts?
The death of hidden offshore accounts
By of MillarLaw A Professional Corporation On Sunday, January 4, 2015
The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The link below is to a video summary of the predicted consequences of the new agreement. http://www.dw.de/interview-with-achim-pross-of-the-oecd/av-18029709 What … Continue reading The death of hidden offshore accounts
Happy Holidays – There is a Budget Deal, Now Look Out
By of MillarLaw A Professional Corporation On Sunday, December 14, 2014
The just passed budget deal known as Consolidated and Further Continuing Appropriations Act, 2015 contains a reduction in funding for the IRS. The Bill provides a reduction in total IRS funding of $346 million less than last fiscal year. “Internal Revenue Service (IRS): Failing to collect what taxpayers owe leaves the federal budget short about … Continue reading Happy Holidays – There is a Budget Deal, Now Look Out