Posts by Stephen J. Dunn
The Use of John Doe Summonses in Identifying U.S. Persons’ Accounts
John Doe summonses are an expeditious weapon available to the U.S. government in identifying U.S. taxpayers’ foreign financial accounts. Click here for the full text. Other posts of interest: U.S. Persons’ Reporting Obligations Regarding Foreign Financial Assets OVDP Often a Bad Choice for Foreign Accounts Compliance You May Only Need to File Delinquent FBARs Reporting Horrors of…
Read MoreBeneficial Ownership of a Foreign Financial Account
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 Regarding Foreign Financial Assets OVDP Often a Bad Choice for Foreign Accounts Compliance You May Only Need to File Delinquent FBARs Reporting Horrors of Foreign Mutual Funds (“PFICs”) Compliance…
Read MoreIs It A Foreign Account?
The Bank Secrecy Act, 31 USC 5314, authorizes the U.S. Treasury to enact regulations concerning transactions by a United States person with a foreign financial agency. A Regulation under the Bank Secrecy Act, 31 CFR 1010.350(a), provides that, “Each United States person having a financial interest in, or signature or other authority over, a bank,…
Read More