Opting Out of OVDP

Posted on: December 28, 2017 | By: Stephen Dunn | Delinquent FBAR Filing Procedures, Opting Out of OVDP, OVDP, Paths to Compliance, Streamlined Procedures, Uncategorized

Recently, a man called who had first called me in 2015.  When he first called, the man wanted to become compliant with U.S. laws concerning foreign financial accounts. ...

Accelerating Disappearing Itemized Deductions Into 2017

Posted on: December 23, 2017 | By: Stephen Dunn | Itemized Deductions, Tax Cut and Jobs Act

The Tax Cut and Jobs Act (“TCJA”) just signed into law by President Trump sharply curtails your ability to claim itemized deductions after 2017.   So, you should try...

Why You Need an Attorney in Charge of Your Foreign Accounts Compliance Case

Posted on: November 22, 2017 | By: Stephen Dunn | Accountant-Client Privilege, Accountants, Attorney-Client Privilege, Bank Secrecy Act, Delinquent FBAR Filing Procedures, FBARs, Financial Advisors, Foreign Assets Compliance, Form 8938, Organizers, OVDP

Accountants commonly send an “organizer” to a client with instructions to complete and sign it and return it to the accountant.  The completed organizer then serves as the...

Tax Evasion Is Most Serious Charge in Indictment of Manafort, Gates

Posted on: November 10, 2017 | By: Stephen Dunn | Bank Secrecy Act, Criminal Tax Prosecutions, FBARs, Foreign Agents Regiatration Act (FARA), Voluntary Disclosures

MnaBy Stephen J. Dunn Tax evasion is the most serious charge in the recent Indictment of Paul J. Manafort, Jr. and Richard W. Gates III. The Indictment avers...

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

The United States does not tax a parent corporation on the earnings of its subsidiary until the subsidiary distributes the earnings to the parent as a dividend.  This...

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 name...

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 | Delinquent FBAR Filing Procedures, 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 | Delinquent FBAR Filing Procedures, 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 | 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...