You Skipped OVDP, now the IRS has initiated an Audit

By Ani Galyan of MillarLaw A Professional Corporation On Sunday, May 15, 2016

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act purposes. In addition, in June of 2014 the IRS announced the Streamlined Procedures to further encourage Taxpayers to come forward and remedy … Continue reading You Skipped OVDP, now the IRS has initiated an Audit

Can Spys and Criminals Make Voluntary Disclosures?

By Sanford Millar of MillarLaw A Professional Corporation On Monday, August 10, 2015

A recent article about convicted spy Jonathan Pollard speculated about the effects on his parole if he had an unreported foreign financial account. The simple truth is that Mr. Pollard would be ineligible for the Offshore Voluntary Disclosure Program (OVDP) if he held direct or beneficial ownership in a foreign financial account(s) which had $10,000 … Continue reading Can Spys and Criminals Make Voluntary Disclosures?

IRS-State Information Sharing Agreements

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, August 2, 2015

The IRS published a list of Information Exchange  agreements it has with state agencies, a copy of which is available here IRS State Information Exchange Table.pdf The disclosure of this list may help taxpayer’s and practitioner’s determine when and possibly whether to file late or amended state or municipal returns. Example 1:  Assume a taxpayer … Continue reading IRS-State Information Sharing Agreements

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

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

Orwell’s 1984 30 Year Later

By of MillarLaw A Professional Corporation On Sunday, November 2, 2014

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax Transparency convened by the OECD/G20 51 countries signed on to the automatic exchange … Continue reading Orwell’s 1984 30 Year Later