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....

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...

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.

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.

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, FBARs, Filing Delinquent 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

By Stephen J. Dunn 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...

Beware Of Swiss Banks Urging OVDP

Posted on: June 8, 2014 | By: Stephen Dunn | Bank Secrecy Act, FBARs, Foreign Assets Compliance, OVDP

By Stephen J. Dunn A client recently received a letter from a Swiss bank “strongly encouraging” the client to enter the Internal Revenue Service (“IRS”) Offshore Voluntary Disclosure...

Foreign Accounts? Don’t Rush Into OVDP

Posted on: May 12, 2014 | By: Stephen Dunn | Bank Secrecy Act, FBARs, Filing Delinquent FBARs, Foreign Assets Compliance, OVDP

By Stephen J. Dunn There are two reasons for a taxpayer to enter the IRS’ Offshore Voluntary Disclosure Program (“OVDP”).  First, to avoid a criminal prosecution.  Second, to...