Dunn Counsel PLC http://www.dunncounsel.com Stephen Dunn Thu, 21 Sep 2017 19:40:08 +0000 en-US hourly 1 https://wordpress.org/?v=4.8.2 http://www.dunncounsel.com/wp-content/uploads/2017/05/cropped-favicon-32x32.png Dunn Counsel PLC http://www.dunncounsel.com 32 32 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 http://www.dunncounsel.com/blog/congress-cannot-tax-undistributed-earnings-u-s-corporations-foreign-subsidiaries#respond Wed, 20 Sep 2017 01:55:39 +0000 http://www.dunncounsel.com/?p=1603 By Stephen J. Dunn 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 ...

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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 ...

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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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U.S. Persons’ Reporting Obligations Regarding Foreign Financial Assets http://www.dunncounsel.com/blog/reporting-obligations-regarding-foreign-financial-assets Mon, 31 Oct 2016 04:09:45 +0000 http://www.dunncounsel.com/?p=1002 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 U.S. income tax return, and reporting foreign financial assets on a Form 8938, Statement of Specified Foreign Financial Assets, filed with a U.S. income tax return.  The ...

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Conflicts of Interest in Handling Foreign Financial Accounts Cases http://www.dunncounsel.com/blog/conflicts-interest-handling-foreign-financial-accounts-cases Tue, 16 Aug 2016 00:36:32 +0000 http://www.dunncounsel.com/?p=977              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 Financial Accounts, (“FBARs”), or amended FBARs reporting foreign financial accounts, and file them.   We have amended income tax returns prepared for clients reporting income from foreign financial ...

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