Foreign Accounts Compliance Blog

Foreign Accounts Compliance Blog

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…

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…

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…

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…

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…

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