Foreign Accounts Compliance

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include reporting the accounts and income therefrom on U.S....

The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets.  The reporting obligations include reporting worldwide income on an annual...

             We assist persons in complying with U.S. laws concerning foreign financial accounts. We prepare FinCEN Forms 114 (formerly Form TD F 90-22.1), Report of Foreign Bank and...

          There are millions of individuals of Indian descent living in the United States.  Many of them left financial assets in India upon immigrating to...

Competent counsel should represent U.S. taxpayers who have failed to file FBARs reporting foreign financial accounts, or who have failed to report foreign financial assets or income therefrom...

Foreign mutual funds, known as passive foreign investment companies or "PFICs," pose significant compliance burdens for U.S. taxpayers.  Click here for the full article. Other posts of interest:...

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...

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...

Tax treaties, intergovernmental information exchange agreements, and the dilution of Swiss banking secrecy laws enable the U.S. government to identify U.S. taxpayers' foreign financial accounts.  Click here for...

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 This is a version of an article originally published in the Winter 2014 issue of the White Collar Crime Committee Newsletter, Criminal Justice Section,...

By Stephen J. Dunn On April 5, 2004, Ms. Ann Dunn Aldrich wrote her Will on an “E–Z Legal Form.” In Article III, entitled “Bequests,” just after the...

By Stephen J. Dunn I have often posted on “tax resolution” firms, which prey upon taxpayers facing IRS collection action. They reach taxpayers in various ways.  Most notoriously,...

By Stephen J. Dunn Having one or more of your tax returns selected for examination by the Internal Revenue Service is indeed a stoke of misfortune.  But there...

By Stephen J. Dunn The IRS has an awesome levy power, enabling it to seize property without a judgment. The IRS uses the power primarily to get the...

“Tax Resolution” Firms I have repeatedly posted on the perils of “tax resolution” firms.  These operators are nominally attorneys, CPAs, or Enrolled Agents.  Their business consists of inducing...

By Stephen J. Dunn The following tips are limited, except where noted, to cash basis taxpayers.  They suggest ways of accelerating deductions into 2013, and should not be...

By Stephen J. Dunn As an entrepreneur, the form of entity you want for your business is not a general partnership, but a corporation or a limited liability company. State...

[caption id="" align="alignright" width="0"] Panel: Loan Reinstatements: How Will They Alter Bankruptcy Reorganizations? (Photo credit: djevents)[/caption] By Stephen J. Dunn Often I express the view that bankruptcy rarely...

By Stephen J. Dunn You cannot rely upon Congress to provide for the long-term solvency of the Social Security trust fund.   You need to provide for your own retirement.  Your first...

Internal Revenue Code § 7508 postpones certain Federal tax obligations for individuals serving in a combat zone.  The postponed obligations include: Filing tax returns. Paying taxes. Filing claims...

[caption id="" align="alignright" width="300"] Logo of Internal Revenue Service, USA (Photo credit: Wikipedia)[/caption] By Stephen J. Dunn A Federal tax lien is not a piece of paper.   It...