Foreign Accounts Compliance Update

Posted on: September 2, 2019 | By: Stephen Dunn | Delinquent International Information Return Submission Procedures, Foreign Accounts Compliance, International Information Returns, Voluntary Disclosure Practice (VDP)

The first thing a taxpayer should do who is out of compliance with United States laws concerning foreign financial accounts is immediately file delinquent FinCEN Forms 114, Report...

Offshore Accounts Remain IRS Enforcement Priority

Posted on: May 16, 2019 | By: Stephen Dunn | Bank Secrecy Act, Delinquent FBAR Submission Procedures, FBAR, Form 3520, Form 3520-A, Form 5471, Form 8865, Form 8938, Form 926, International Information Returns, Statute of Limitations, Streamlined Procedures, The FBAR Filing Requirement, Uncategorized

At the American Bar Association Taxation Section’s annual meeting in Washington, D.C., in May, 2019, IRS representatives said the IRS continues examining evidence of Americans’ foreign financial accounts,...

International Information Returns

Posted on: December 22, 2018 | By: Stephen Dunn | FBAR, Form 3520, Form 3520-A, Form 8865, Form 8938, Form 926, International Information Returns, Uncategorized

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires U.S. taxpayers to file information returns concerning foreign assets, accounts, and...

The FBAR Filing Requirement

Posted on: December 22, 2018 | By: Stephen Dunn | Bank Secrecy Act, Draconian FBAR Penalty, FBAR, FBARs, Foreign Accounts Compliance, International Information Returns, The FBAR Filing Requirement, Uncategorized

The United States taxes its citizens and residents on their worldwide income.  To evade U.S. income tax, U.S. taxpayers were transferring their funds to foreign financial institutions, which...

Americans’ Interests in Foreign Partnerships Reportable on Form 8865

Posted on: December 15, 2018 | By: Stephen Dunn | Delinquent International Information Return Submission Procedures, Form 8865, International Information Returns, Uncategorized

A U.S. taxpayer whose interest in a foreign partnership meets a specified threshold must file with his U.S. income tax return Form 8865, Return of U.S. Persons With...

Americans’ Interests in Foreign Accounts Reportable on Form 8938

Posted on: December 15, 2018 | By: Stephen Dunn | Delinquent International Information Return Submission Procedures, Form 8938, International Information Returns, Uncategorized

The United States taxes its citizens and residents on their worldwide income.  Accordingly, the U.S. Internal Revenue Code requires U.S. taxpayers whose interests in foreign financial accounts exceed...

Forms 3520 and 3520-A and the Grantor Trust Rules

Posted on: November 10, 2018 | By: Stephen Dunn | Delinquent International Information Return Submission Procedures, Foreign Trusts, Form 3520, Form 3520-A, International Information Returns, Streamlined Procedures, Uncategorized

The United States taxes its citizens and residents on their worldwide income.  To ascertain U.S. taxpayers’ foreign income, the Internal Revenue Service requires the filing of a series...

Mysterious Form 926

Posted on: October 25, 2018 | By: Stephen Dunn | Delinquent International Information Return Submission Procedures, Foreign Accounts Compliance, Foreign Transactions, Form 926, International Information Returns

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires the filing of a series of information returns by U.S. taxpayers...

Shareholders in Closely-Held Foreign Corporations: Beware Form 5471

Posted on: October 8, 2018 | By: Stephen Dunn | Controlled Foreign Corporations, Delinquent International Information Return Submission Procedures, Foreign Accounts Compliance, Form 5471, International Information Returns, Uncategorized

A U.S. taxpayer whose interest in a closely-held foreign corporation meets a specified threshold must file Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign...