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...

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...

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...

Who Should Represent U.S. Taxpayers Concerning Foreign Assets

Posted on: March 18, 2016 | By: Stephen Dunn | Attorney-Client Privilege, Delinquent FBAR Filing Procedures, 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...

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...