Estate Tax Repeal Would Harm the Middle Class

Posted on: October 17, 2017 | By: Stephen Dunn | Estate and Gift Taxation, Estate Planning, Tax Reform

By Stephen J. Dunn Repeal of the Federal estate tax would harm the middle class by depriving them of the basis step-up in property received from a decedent....

Why Congress Cannot Tax the Undistributed Earnings of U.S. Corporations’ Foreign Subsidiaries

Posted on: September 20, 2017 | By: Stephen Dunn | Controlled Foreign Corporations, U.S. Corporations' Foreign Subsidiaries

By Stephen J. Dunn The United States does not tax a parent corporation on the earnings of its subsidiary until the subsidiary distributes the earnings to the parent...

Foreign Accounts? Here’s What You Need to Know

Posted on: July 8, 2017 | By: Stephen Dunn | Draconian FBAR Penalty, FBARs, Foreign Assets Compliance, Form 8938, Passive Foreign Investment Companies ("PFICs")

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            FBARs If the total balance of your foreign financial accounts exceeds $10,000 at any time during a calendar year, then you must file an “FBAR” (the actual...

OVDP Often a Bad Choice for Foreign Accounts Compliance

Posted on: June 26, 2017 | By: Stephen Dunn | Foreign Assets Compliance, OVDP, Streamlined Procedures

The Internal Revenue Service’s Offshore Voluntary Disclosure Program (“OVDP”) is the most costly and administratively burdensome means of complying with U.S. laws concerning foreign financial accounts.  Very few...

Our Approach to Foreign Accounts Cases

Posted on: June 6, 2017 | By: Stephen Dunn | FBARs, Filing Delinquent FBARs, Foreign Assets Compliance, OVDP, Streamlined Procedures

We place clients into compliance with United States laws concerning foreign financial accounts with the least possible work and expense. In a typical case, a taxpayer or taxpayer’s...

Compliance Required of U.S. Persons Concerning Foreign Financial Accounts

Posted on: June 1, 2017 | By: Stephen Dunn | FBARs, Filing Delinquent FBARs, Foreign Assets Compliance, OVDP, Streamlined Procedures

U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the Bank Secrecy Act. A prior article explores who...

Reporting Horrors of Foreign Mutual Funds (“PFICs”)

Posted on: April 24, 2017 | By: Stephen Dunn | Featured, Foreign Assets Compliance, Passive Foreign Investment Companies ("PFICs")

U.S.-based mutual funds annually issue to each of their shareholders a Form 1099 reporting the shareholder’s share of interest, dividends, and capital gains realized by the mutual fund...

Beneficial Ownership, Income Tax, and FBARs

Posted on: February 2, 2017 | By: Stephen Dunn | Bank Secrecy Act, Beneficial Ownership, FBARs, Featured, Foreign Assets Compliance

For U.S. income tax purposes, ownership of property means beneficial ownership.  Only the beneficial owner of property is required to report taxable income from the property on a...

You May Only Need to File Delinquent FBARs

Posted on: February 2, 2017 | By: Stephen Dunn | Bank Secrecy Act, FBARs, Featured, Filing Delinquent FBARs, Foreign Assets Compliance, OVDP, Streamlined Procedures

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include reporting the accounts and income therefrom on U.S....

U.S. Persons’ Reporting Obligations Regarding Foreign Financial Assets

Posted on: October 31, 2016 | By: Stephen Dunn | Foreign Assets Compliance

The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets.  The reporting obligations include reporting worldwide income on an annual...