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?
California Steps Up Criminal Tax Enforcement
By Sanford Millar of MillarLaw A Professional Corporation On Monday, April 25, 2016
California has a multi-agency task force known as the Revenue Recovery and Enforcement Team that was established to attack criminal tax evasion. The stated goals of the team are: (a) According to the State Board of Equalization, an estimated nine billion dollars ($9,000,000,000) in corporate, personal, and sales and use taxes goes uncollected in California … Continue reading California Steps Up Criminal Tax Enforcement
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?
Justice Department Focusing on Offshore Account
By Sanford Millar of MillarLaw A Professional Corporation On Sunday, October 11, 2015
At a recent tax conference a senior Justice Department official reaffirmed thte commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated: “We are well beyond Switzerland at this point,” she said, citing enforcement announcements concerning India, Israel, Liechtenstein, Panama, the British Virgin Islands, and, most … Continue reading Justice Department Focusing on Offshore Account
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!!!
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