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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MillarLaw is a Los Angeles-based tax law practice specializing in complex domestic and international tax matters. The firm provides legal guidance and representation for individual and business clients worldwide, focusing on tax planning, voluntary disclosures, and tax controversies at both federal and state levels. MillarLaw emphasizes quality and thorough problem-solving over high caseload volume, aiming to secure positive outcomes in high-stakes tax issues. The firm also shares insights through its blog, covering topics such as tax consequences of casualty losses, cryptocurrency taxation, mental incapacity defenses in tax penalties, audit limitations, and international tax enforcement priorities.
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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…