Foreign Accounts Compliance Blog

VDP—IRS’ Updated Voluntary Disclosure Practice

The Internal Revenue Service ended its Offshore Voluntary Disclosure Program (“OVDP”) effective September 28, 2018. Since then the IRS has ...
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Offshore Accounts Remain IRS Enforcement Priority

At the American Bar Association Taxation Section’s annual meeting in Washington, D.C., in May, 2019, IRS representatives said the IRS ...
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Streamlined Procedures for Foreign Accounts Compliance

Posted on: January 9, 2019 | By: Dunn Counsel |  Bank Secrecy Act, Paths to Compliance, Streamlined Procedures, The FBAR Filing Requirement, Uncategorized Many Americans become ...
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International Information Returns

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires U.S. taxpayers to ...
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Americans’ Interests in Foreign Partnerships Reportable on Form 8865

A U.S. taxpayer whose interest in a foreign partnership meets a specified threshold must file with his U.S. income tax ...
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Forms 3520 and 3520-A and the Grantor Trust Rules

The United States taxes its citizens and residents on their worldwide income.  To ascertain U.S. taxpayers’ foreign income, the Internal ...
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Mysterious Form 926

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires the filing of ...
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Shareholders in Closely-Held Foreign Corporations: Beware Form 5471

A U.S. taxpayer whose interest in a closely-held foreign corporation meets a specified threshold must file Form 5471, Information Return ...
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Required Reporting of Foreign Financial Accounts

U.S. persons are required to report to the United States government concerning foreign financial accounts. A “U.S. person” is a ...
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Why You Need an Attorney in Charge of Your Foreign Accounts Compliance Case

Accountants commonly send an “organizer” to a client with instructions to complete and sign it and return it to the ...
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