Welcome to Our New Website!!
Welcome to Our New Website! By: Stephen J. Dunn 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 […]
Due Process of Law in Federal Tax Assessments
Due Process of Law in Federal Tax Assessments By: Stephen J. Dunn 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 […]
Relief from International Information Return Penalties for Doctors Victimized by Foreign Trust Schemes
Relief from International Information Return Penalties for Doctors Victimized by Foreign Trust Schemes By: Stephen J. Dunn 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 […]
Section 6751(b)(1) and Written, Supervisory Approval of Penalties
Section 6751(b)(1) and Written, Supervisory Approval of Penalties By: Stephen J. Dunn 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 […]
United States Income Taxation of United Kingdom-Based Pension Plans
United States Income Taxation of United Kingdom-Based Pension Plans By: Stephen J. Dunn 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 […]