Category: Uncategorized

The Internal Revenue Service ended its Offshore Voluntary Disclosure Program (“OVDP”) effective September 28, 2018. Since then the IRS has made its Voluntary Disclosure Practice (“VDP”) available to...

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,...

Many Americans become compliant with U.S. laws concerning foreign financial accounts by means of the Streamlined Filing Compliance Procedures (the “Streamlined Procedures”). To qualify for the Streamlined Procedures,...

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 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...

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...

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...

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...

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...

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...

By Stephen J. Dunn On receiving his monthly bank statements, a small business owner notices that the United States government has seized the balances of his accounts during...

By Stephen J. Dunn I have represented undocumented aliens (I do not call them “illegal” aliens, as I am unwilling to accept that there is such a thing...

By Stephen J. Dunn Payroll service providers are a big deal for small business─an estimated 41% of American small businesses use them. The services provided by PSPs range...

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 At a recent debate in Iowa, candidate Newt Gingrich backed a plan to allow undocumented aliens who have been living in this country for...

Your  Majesty: An American of Irish descent, I welcome your visit to Ireland.  It is the first Royal visit to Ireland since Ireland gained its independence in 1921. ...

By Stephen J. Dunn It is important that you manage your credit reports.    Your credit reports determine whether you can access credit, and the terms on which you...

By Stephen J. Dunn The Founding Fathers never knew an income tax.  They created a country of limited government.   We did not have a Federal income tax until...

By Stephen J. Dunn As the tax filing deadline fast approaches, you should pause before signing a joint income tax return.  You are not liable for income tax...

By Stephen J. Dunn In 25 years of law practice I have done estate planning for hundreds of people.  Every one of them has wanted a health care...

By Stephen J. Dunn The just-enacted Tax Relief, Unemployment Insurance Authorization, and Job Creation Act of 2010 makes great strides against the Federal estate tax burden that otherwise...

By Stephen J. Dunn Our country has proved time and again that a tax cut can energize our economy and bring us out of a recession. In 1921,...

By Stephen J. Dunn Tax resolution firms are a misnomer.  They exact high fees from unassuming consumers and seldom resolve anything.   These firms are a relatively recent development,...