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...

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...

Beneficial Ownership, Income Tax, and FBARs

Posted on: February 2, 2017 | By: Stephen Dunn | Bank Secrecy Act, Beneficial Ownership, FBARs, 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, Delinquent FBAR Filing Procedures, 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...