Dunn Counsel PLC http://www.dunncounsel.com Stephen Dunn Wed, 22 Nov 2017 17:07:12 +0000 en-US hourly 1 https://wordpress.org/?v=4.8.3 http://www.dunncounsel.com/wp-content/uploads/2017/05/cropped-favicon-32x32.png Dunn Counsel PLC http://www.dunncounsel.com 32 32 Why You Need an Attorney in Charge of Your Foreign Accounts Compliance Case http://www.dunncounsel.com/blog/why-you-need-an-attorney-in-charge-of-your-foreign-accounts-compliance-case-2 http://www.dunncounsel.com/blog/why-you-need-an-attorney-in-charge-of-your-foreign-accounts-compliance-case-2#respond Wed, 22 Nov 2017 03:52:34 +0000 http://www.dunncounsel.com/?p=2070 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 starting point for preparation of the client’s annual income tax returns.  The problem is that there is no accountant-client privilege in Federal court, and a completed organizer ...

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Tax Evasion Is Most Serious Charge in Indictment of Manafort, Gates http://www.dunncounsel.com/blog/tax-evasion-is-most-serious-charge-in-indictmnt-of-manafort-gates http://www.dunncounsel.com/blog/tax-evasion-is-most-serious-charge-in-indictmnt-of-manafort-gates#respond Fri, 10 Nov 2017 18:06:03 +0000 http://www.dunncounsel.com/?p=1844 By 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 that Manafort and Gates engaged in a multi-million dollar lobbying campaign for Victor Yanukovych, then-President of Ukraine, before he fled to Russia, and the Government of Ukraine.  ...

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Why Congress Cannot Tax the Undistributed Earnings of U.S. Corporations’ Foreign Subsidiaries http://www.dunncounsel.com/blog/congress-cannot-tax-undistributed-earnings-u-s-corporations-foreign-subsidiaries Wed, 20 Sep 2017 01:55:39 +0000 http://www.dunncounsel.com/?p=1603 The United States does not tax a parent corporation on the earnings of its subsidiary until the subsidiary distributes the earnings to the parent as a dividend.  This holds true for a U.S. corporation’s foreign subsidiary, provided the foreign subsidiary is not a “controlled foreign corporation,” which I am assuming is the case.  If such ...

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Foreign Accounts? Here’s What You Need to Know http://www.dunncounsel.com/blog/foreign-accounts-heres-need-know Sat, 08 Jul 2017 03:21:34 +0000 http://www.dunncounsel.com/?p=1555 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 is FinCEN Form 114, Annual Report of Foreign Bank and Financial Accounts) with the U.S. government for that year.  An FBAR for a given calendar year is ...

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OVDP Often a Bad Choice for Foreign Accounts Compliance http://www.dunncounsel.com/blog/ovdp-often-bad-choice-foreign-accounts-compliance Mon, 26 Jun 2017 10:06:53 +0000 http://www.dunncounsel.com/?p=1530 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 people are a candidate for the OVDP.  It applies only to people whose noncompliance with U.S. laws concerning foreign financial accounts was willful. Most people do not ...

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Our Approach to Foreign Accounts Cases http://www.dunncounsel.com/blog/approach-foreign-accounts-cases Tue, 06 Jun 2017 18:27:25 +0000 http://dunncounsel.wpdev.webascender.host/?p=1445 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 representative calls us explaining that the taxpayer is out of compliance with U.S. laws concerning foreign financial assets. We assure the individual calling that our communications are ...

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Compliance Required of U.S. Persons Concerning Foreign Financial Accounts http://www.dunncounsel.com/blog/compliance-required-u-s-persons-concerning-foreign-financial-accounts Thu, 01 Jun 2017 18:07:30 +0000 http://dunncounsel.wpdev.webascender.host/?p=1416 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 is a “U.S. person.” Internal Revenue Code A U.S. person is subject to compliance obligations under the Internal Revenue Code only with respect to foreign financial accounts ...

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Reporting Horrors of Foreign Mutual Funds (“PFICs”) http://www.dunncounsel.com/blog/reporting-horrors-foreign-mutual-funds-pfics Mon, 24 Apr 2017 18:56:33 +0000 http://www.dunncounsel.com/?p=1167 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 during the year.

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Beneficial Ownership, Income Tax, and FBARs http://www.dunncounsel.com/blog/beneficial-ownership-foreign-accounts Thu, 02 Feb 2017 16:49:19 +0000 http://www.dunncounsel.com/?p=1015 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 U.S. income tax return.

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You May Only Need to File Delinquent FBARs http://www.dunncounsel.com/blog/you-may-only-need-to-file-delinquent-fbars Thu, 02 Feb 2017 16:40:32 +0000 http://www.dunncounsel.com/?p=1010 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. income tax returns, and reporting the accounts on FinCEN Forms 114, Report of Foreign Bank and Financial Accounts, (“FBARs”).

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