Welcome to Our New Website!
At last, our new website! This project has been in progress for months, but the press of practice has prevented me from completing it. The purpose is to inform clients and prospective clients of my experience and expertise in providing specialized legal services. Throughout my career I have written for publication. I believe that writing […]
Due Process of Law in Federal Tax Assessments
The Fifth Amendment Due Process Clause applies to tax assessments. This article explores what process is due and what process is afforded in Federal tax assessments. What Process Is Due Amendment V to the U.S. Constitution guarantees due process of law: “No person shall . . . be deprived of life, liberty, or property, without […]
Relief from International Information Return Penalties for Doctors Victimized by Foreign Trust Schemes
Stephen J. Dunn is founder and member of Dunn Counsel PLC, Troy, Michigan. He thanks Joseph Trytten, of the law firm of Golan Christie Taglia, Chicago, for reviewing and commenting on this article. In the 1990s lawyers and others traversed the United States promoting “asset protection” schemes to doctors. The schemes involved transfer of the […]
Section 6751(b)(1) and Written, Supervisory Approval of Penalties
Stephen J. Dunn is the founder and member of Dunn Counsel PLC, Troy, Michigan. He thanks Ryan Peruski for his assistance in reviewing this article. A version of this article first appeared in Tax Notes Federal and Tax Notes International. Copyright 2024 Stephen J. Dunn. All rights reserved. Section 6751(b)(1) provides important due process of […]
United States Income Taxation of United Kingdom-Based Pension Plans
Many United Kingdom citizens reside in the United States having worked all part or all of their career in the U.K. Due to their U.S. citizenship or residency they must comply with U.S. laws concerning their interests in U.K.-based pension plans, and they are subject to heavy penalties for noncompliance with those laws. Voluntary disclosure […]