By: Sanford I. Millar © 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
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When are you safe from a tax audit? Or, All things must pass, maybe!
The most common question I am asked when the subject to taxes comes up in conversation is “how long does the IRS have to audit me?”. The answer of course is, it depends. There are a variety of Statutes of…
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International Enforcement is an IRS Priority: Immigrants are particularly vulnerable
The IRS announced its enforcement priorities include international reporting among the top two categories. I have represented taxpayer’s in disputes with the IRS and state taxing agencies over international and domestic tax issues for decades. What I have found is…
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What do Laurie Loughlin and Al Capone have in common? Answer: Tax Crimes
Don’t get me wrong, I am not suggesting that there is an equivalence in actions between Laurie Loughlin, whose underlying alleged[1] criminal activity involved bribery in an effort to get her daughters into college and the conduct of an organized…
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Why the Paul Manafort Case Matters to You.
Why the Paul Manafort Case Matters to You. Paul Manafort, the former campaign manager for president Donald Trump was sentenced to a term of 47 months in prison this week and ordered to pay millions of dollars in restitution. He…
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Proposition XIII is Under Attack
Proposition XIII is under attack through a proposed amendment to the Constitution of the State of California. The proposed amendment is known as “The California Schools and Local Communities Funding Act of 2018” The proposed amendment would eliminate Prop 13…
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The Taxpayer -Accountant Relationship Is Under Pressure
The beginning of the year is usually a time for thinking about the challenges ahead. This year is no different. The “shutdown” of parts of the federal government, including the IRS, will cause a variety of personal and business hardships…
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The Tax Cuts and Jobs Acts Eliminates the Tax Deduction for Spousal Support Beginning January 1, 2019
The Tax Cuts and Jobs Acts Eliminates the Tax Deduction for Spousal Support Beginning January 1, 2019, except for support Orders effective by December 31, 2018. For decades the Internal Revenue Code and the California Revenue and Taxation Code have…
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The Offshore Voluntary Disclosure Program Ends September 28, 2018. What happens next?
The end of the Offshore Voluntary Disclosure Program (“OVDP”) may mean nothing at all to the hard core taxpayers who will never voluntarily come forward. For many of those individuals. who chose the “wrong” foreign financial institution or financial advisor…
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Accountants: Practice Alert-Dealing With IRS-Criminal Investigation Division
The following is abstracted from an article appearing in the July, 2018 edition of the Journal of taxation (WG&L). It is well written and covers the major points of concern and practice recommendations for an accountant or enrolled agent approached…
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