Stephen J. Dunn, the firm’s founder, was born and raised in Grand Rapids, Michigan the youngest of four brothers.
Mr. Dunn earned his B.S.B.A. cum laude, in Accounting from Aquinas College in 1978. He earned his J.D. from Notre Dame Law School in 1985. He was a Staff Member and Associate Editor of the Notre Dame Law Review. He earned is LL.M. (Taxation), Washington University in St. Louis School of Law, 1991
While at Aquinas College, Mr. Dunn served as a Tax Intern in the Grand Rapids office of BDO (then known as Seidman & Seidman). Upon graduating from Aquinas, he joined the Audit Staff of the Grand Rapids office of Ernst & Young (then known as Ernst & Ernst). Mr. Dunn worked on the largest audits of E&Y’s Grand Rapids office, and could have made a career there. But in 1982 he matriculated at Notre Dame Law School. While at Notre Dame, worked as a law clerk at May, Oberfell & Lorber, South Bend, Indiana, and served as Staff Member and Associate Editor of the Notre Dame Law Review.
In 1985 Mr. Dunn earned his J.D. from Notre Dame, and joined the Varnum law firm (then known as Varnum, Riddering, Wierengo & Christianson) in Grand Rapids, Michigan. In 1987, Mr. Dunn moved to the Thompson Coburn law firm (then known as Thompson & Mitchell), St. Louis, Missouri. Mr. Dunn also began working on LL.M. (Taxation) at Washington University in St. Louis.
Upon earning his LL.M. in 1991, Mr. Dunn moved to Troy, Michigan, where he and his family have lived ever since.
Mr. Dunn is a tax attorney specializing in international taxation, tax controversies, and estate planning. He is especially effective in complex tax controversies.
In recent years, most of Mr. Dunn’s work has involved helping taxpayers comply with U.S. laws concerning foreign financial assets. Mr. Dunn is a leading authority on foreign accounts compliance. He has handled hundreds of foreign accounts compliance cases, including those involving–
- Delinquent FBAR filing procedures.
- Delinquent international information return procedures.
- Streamlined compliance procedures, for residents of the United States and for nonresidents of the United States.
- Offshore Voluntary Disclosure Program (OVDP) cases, from filing through review and closing.
- Withdrawing improvident OVDP cases, at a saving of hundreds of thousands of dollars in penalties to the client, and dealing with consequent IRS review.
- Cases involving personal foreign investment companies (“PFICs”), including Forms 8621, Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund.
- FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (FBAR).
- Forms 8938, Statement of Specified Foreign financial Assets.
- Forms 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations.
- Forms 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships
- Forms 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts.
- Forms 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner.
Mr. Dunn has advised taxpayers concerning IRC § 911 foreign earned income exclusion, and represented them before the Internal Revenue Service in controversies concerning the exclusion.
Throughout his career Mr. Dunn has represented taxpayers in criminal and civil tax cases, including the following:
- Tax assessment cases.
- Tax collection cases, including installment agreements, currently not collectible postings, offers in compromise from levies, as well as tax collection cases.
- Claims for refund.
- State and local tax controversies.
Mr. Dunn has represented many taxpayers before the IRS Appeals Office, in U.S. Tax Court, in U.S. District Court, and in the U.S. Court of Federal Claims.
Mr. Dunn’s published cases include Cor-Bon Custom Bullet Co. v. United States, 287 F.3d 576 (6th Cir.), cert. denied, 537 U.S. 880, 154 L. Ed. 2d 136, 123 S. Ct. 90 (2002); earlier proceedings sub nom. Pi v. United States, 174 F.3d 745 (6th Cir.), cert. denied, 528 U.S. 825, 145 L. Ed. 2d 63, 120 S. Ct. 74 (1999), in which his client, charged with tax evasion, was acquitted by the jury on all counts; and United States v. Fifth Third Bank Account, (E.D. Mich.), in which Mr. Dunn’s clients recovered all of the funds seized from them, 2013 WL 5914101, and all of their legal costs. 2014 WL 861572.
Mr. Dunn is admitted to practice in courts of the States of Michigan (1985) and Missouri (1988); United States District Court for the Western District of Michigan (1985), Eastern District of Missouri (1988), and Eastern District of Michigan (1994); United States Tax Court (1986); United States Court of Federal Claims (1988); United States Court of Appeals for the Eighth Circuit (1988), the Federal Circuit (1988), and the Sixth Circuit (1998); United States Supreme Court (1999).
Throughout his career Mr. Dunn has performed estate planning. He is expert in federal estate and gift taxation. He has planned large estates, including those involving closely-held businesses.
Writing is an essential skill for a lawyer. Mr. Dunn does a lot of writing. He have written a treatise, Foreign Accounts Compliance (Thomson Reuters), and updates it annually. He plans to write another treatise, U.S. Taxation of Immigrants.
Mr. Dunn writes a blog, Foreign Accounts Compliance. He has also blogged for Bloomberg, Forbes, and Newsmax.
Mr. Dunn and his wife, Geri, and have three grown children and ten grandchildren. He runs regularly, and follows the Detroit Tigers, the Detroit Lions, and the Detroit Red Wings.