VDP—IRS’ Updated Voluntary Disclosure Practice
By Stephen J. Dunn |
The Internal Revenue Service ended its Offshore Voluntary Disclosure Program (“OVDP”) effective September 28, 2018. Since then the IRS has ...
Read More Offshore Accounts Remain IRS Enforcement Priority
By Stephen J. Dunn |
At the American Bar Association Taxation Section’s annual meeting in Washington, D.C., in May, 2019, IRS representatives said the IRS ...
Read More Streamlined Procedures for Foreign Accounts Compliance
By Stephen J. Dunn |
Posted on: January 9, 2019 | By: Dunn Counsel | Bank Secrecy Act, Paths to Compliance, Streamlined Procedures, The FBAR Filing Requirement, Uncategorized Many Americans become ...
Read More International Information Returns
By Stephen J. Dunn |
The United States taxes its citizens and residents on their worldwide income. The Internal Revenue Service requires U.S. taxpayers to ...
Read More Americans’ Interests in Foreign Partnerships Reportable on Form 8865
By Stephen J. Dunn |
A U.S. taxpayer whose interest in a foreign partnership meets a specified threshold must file with his U.S. income tax ...
Read More Forms 3520 and 3520-A and the Grantor Trust Rules
By Stephen J. Dunn |
The United States taxes its citizens and residents on their worldwide income. To ascertain U.S. taxpayers’ foreign income, the Internal ...
Read More Mysterious Form 926
By Stephen J. Dunn |
The United States taxes its citizens and residents on their worldwide income. The Internal Revenue Service requires the filing of ...
Read More Shareholders in Closely-Held Foreign Corporations: Beware Form 5471
By Stephen J. Dunn |
A U.S. taxpayer whose interest in a closely-held foreign corporation meets a specified threshold must file Form 5471, Information Return ...
Read More Required Reporting of Foreign Financial Accounts
By Stephen J. Dunn |
U.S. persons are required to report to the United States government concerning foreign financial accounts. A “U.S. person” is a ...
Read More Why You Need an Attorney in Charge of Your Foreign Accounts Compliance Case
By Stephen J. Dunn |
Accountants commonly send an “organizer” to a client with instructions to complete and sign it and return it to the ...
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