Category: Foreign Accounts Compliance

Congress enacted the FBAR filing obligation, and the draconian penalty for failure to discharge the obligation, to curb the use of foreign accounts to evade U.S. income tax. ...

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...

A client recently received a letter from a Swiss bank “strongly encouraging” the client to enter the Internal Revenue Service (“IRS”) Offshore Voluntary Disclosure Program (“OVDP”).  The letter...

There are two reasons for a taxpayer to enter the IRS’ Offshore Voluntary Disclosure Program (“OVDP”).  First, to avoid a criminal prosecution.  Second, to avoid the draconian civil...

By Stephen J. Dunn The Bank Secrecy Act and the Internal Revenue Code both require reporting by United States persons concerning their foreign financial accounts. For purposes of both acts,...

By Stephen J. Dunn FBAR The United States taxes its citizens and its resident aliens on their worldwide income. U.S. taxpayers are required to report their foreign income...

By Stephen J. Dunn Facebook co-founder Eduardo Saverin caused a stir recently by moving to Singapore and renouncing his U.S. citizenship. In so doing he halved the income...

By Stephen J. Dunn The United States taxes its citizens and resident aliens on their worldwide income. U.S. law prevents double taxation by allowing a credit for foreign...

By Stephen J. Dunn The United States taxes its citizens and resident aliens on their worldwide income, allowing income tax which they must pay to foreign jurisdictions as...

By Stephen J. Dunn U.S. tax law taxes U.S. citizens and resident aliens on their worldwide income.  Many U.S. taxpayers have attempted to evade U.S. income tax by...