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BIO

Sanford MillarSanford I. Millar is a Certified Specialist in Taxation Law and is admitted to practice before all courts in the State of California.

Mr. Millar is rated AV® PreeminentTM 5.0 out of 5 by Martindale-Hubbell, and named a Southern California Super Lawyer 2006–2010 (Los Angeles Magazine/Law & Politics Magazine).

Based in Los Angeles, where he has practiced for since 1974, Mr. Millar has represented clients in diverse businesses in domestic and complex cross-border transactions. He is skilled at international tax planning and international tax controversy and compliance matters for entrepreneurial companies, high net worth and dual national individuals.  His experience  includes helping clients: (a) structure the sale of a partnership interest in an international cellular phone company,(b) structuring international internet game companies, (c) restructure failed asset protection plans, (d) foreign bank and financial account compliance problems,(e) voluntary disclosures  and (f) other financial asset problems . He has a sub-specialty in taxation of eCommerce including Internet gaming. He is frequently consulted as an expert on business and taxation law matters in the gaming and non-gaming sectors.

  • Mr. Millar is a Commissioner on the Taxation Law Advisory Commission of the State Bar of California.
  • He is vice-chair of the Tax Policy, Practice and Legislation Committee of the State Bar of California.
  • He is a member of the Executive Committee of the International Law Committee of the State Bar of California.  
  • He is  chair of the International Law Section of the Beverly Hills Bar Association
  • He is an instructor at UCLA Extension where he teaches taxation law.
  • He has served as an instructor at the University of Southern California, Graduate School of Business Leventhal School of Accounting, where he taught advanced corporate taxation and tax procedure and at California State University Northridge in the Masters in Science in Taxation program.
  • He has  lectured for the Practising Law Institute and California Continuing Education of the Bar on taxation law and closely held business  issues.
  • He has testified before the State Senate of California and has lectured to members of many professional associations and industry groups.

Mr. Millar obtained an A.B degree in 1971 from the University of Southern California in International Relations, a Juris Doctor from Southwestern University School of Law in 1974 and a Masters in Business Taxation from the University of Southern California, Graduate School of Business in 1982.  He also attended post-graduate classes at the RAND Graduate School.

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Areas of practice include:

Tax: Federal, state and local tax compliance, including tax planning for international or domestic transactions, tax disputes and tax crimes. Planning services include formation of business enterprises, operational planning and dissolution planning. Compliance services include audit planning and representation, planning for dual nationals,  foreign asset and financial account issues, such as FBAR’s and Voluntary Disclosures and expatriation planning.

Gaming: eCommerce, including internet gaming and gaming law compliance.

Typical Clients: Clients range from individuals and entrepreneurs to multi-national enterprises, tribal coalitions and non-governmental organizations.

Typical Problems: The problems have a common theme which is dealing with a serious tax, Bank Secrecy Act, (FBAR), foreign financial accounts or other regulatory compliance (such as Internet gaming) issue. Many issues are international in scope and involve treaty interpretation. Some cases involve bankruptcy tax planning or asset protection or tax planning in family law matters.

BLOG POSTS

  • Is the Tax Adviser Privilege a Trap fo the Unwary?

    As we approach April 15th many taxpayers will meet with professional tax advisers and some may be under the impression that communications between a taxpayer and a tax adviser are privileged. This assumption is wrong as demonstrated by a case now on appeal from the Ninth Circuit to the U.S. Supreme Court (Edwards v. The [...]

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  • Innocent Spouse Relief has Been Made Easier

    In Notice 2012-8 the IRS has improved the possibility of “Innocent Spouse” claims for relief from tax liability being granted. The new factors that the IRS will take into consideration are actual abuse or lack of financial control. The actual abuse in the form of physical intimidation is best proven through police reports of domestic [...]

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  • To DIsclose Or Not-Foreign Asset Issues

    The IRS recently extended the Offshore Voluntary Disclosure Initiative (OVDI)only this time without a deadline. The miscellaneous civil penalty was increase to 27.5% from 25% of the highest single year foreign financial account balance. That cost may have a chilling effect on participation, but it should not for some taxpayers. One of the benefits of [...]

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  • Foreign Assets; What Must I Disclose?

    Beginning with income tax returns for 2011, U.S. individual taxpayers must attach a statement (Form 8938) to their return if they hold an interest in “specified foreign financial interests” and the value of those interests exceed certain thresholds. Example for an individual the threshold is $50,000 at year end or $75,000 at anytime during the [...]

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