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...

Conflicts of Interest in Handling Foreign Financial Accounts Cases

Posted on: August 15, 2016 | By: Stephen Dunn | Bank Secrecy Act, Conflicts of Interest in Handling Foreign Financial Accounts Cases, FBARs, Filing Delinquent FBARs, Foreign Assets Compliance, OVDP, Streamlined Procedures

             We assist persons in complying with U.S. laws concerning foreign financial accounts. We prepare FinCEN Forms 114 (formerly Form TD F 90-22.1), Report of Foreign Bank and...

Disclosure of Indian Financial Accounts to U.S. Government

Posted on: July 16, 2016 | By: Stephen Dunn | Disclosure of Indian Financial Accounts to the U.S. Government, Foreign Assets Compliance

          There are millions of individuals of Indian descent living in the United States.  Many of them left financial assets in India upon immigrating to...

Who Should Represent U.S. Taxpayers in Foreign Assets Compliance Cases

Posted on: March 18, 2016 | By: Stephen Dunn | Attorney-Client Privilege, FBARs, Filing Delinquent FBARs, Foreign Assets Compliance, OVDP, Passive Foreign Investment Companies ("PFICs"), Streamlined Procedures

Competent counsel should represent U.S. taxpayers who have failed to file FBARs reporting foreign financial accounts, or who have failed to report foreign financial assets or income therefrom...