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...

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....

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, Delinquent FBAR Filing Procedures, 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...

Beneficial Ownership of a Foreign Financial Account

Posted on: January 2, 2016 | By: Stephen Dunn | Bank Secrecy Act, Beneficial Ownership, FBARs, Foreign Assets Compliance

Beneficial ownership is a pivotal yet elusive concept in the foreign financial accounts arena.  Click here for the full article. Other posts of interest: U.S. Persons' Reporting Obligations...

The Use of John Doe Summonses in Identifying U.S. Persons’ Accounts

Posted on: January 2, 2016 | By: Stephen Dunn | Bank Secrecy Act, FBARs, Foreign Assets Compliance, John Doe Summnses

John Doe summonses are an expeditious weapon available to the U.S. government in identifying U.S. taxpayers' foreign financial accounts.  Click here for the full text. Other posts of...

Status of Intergovernmental Information Sharing Concerning U.S. Persons’ Foreign Financial Accounts

Posted on: January 1, 2016 | By: Stephen Dunn | Bank Secrecy Act, FBARs, Foreign Assets Compliance, Intergovernmental Information Sharing

Tax treaties, intergovernmental information exchange agreements, and the dilution of Swiss banking secrecy laws enable the U.S. government to identify U.S. taxpayers' foreign financial accounts.  Click here for...

Filing Delinquent FBARs

Posted on: August 21, 2014 | By: Stephen Dunn | Bank Secrecy Act, Delinquent FBAR Filing Procedures, FBARs, Foreign Assets Compliance

Congress enacted the FBAR filing obligation, and the draconian penalty for failure to discharge the obligation, to curb the use of foreign accounts to evade U.S. income tax. ...

Is It A Foreign Account?

Posted on: July 14, 2014 | By: Stephen Dunn | Bank Secrecy Act, FBARs, Foreign Assets Compliance, Uncategorized

The Bank Secrecy Act, 31 USC 5314, authorizes the U.S. Treasury to enact regulations concerning transactions by a United States person with a foreign financial agency.  A Regulation under the...