Compliance Required of U.S. Persons Concerning Foreign Financial Accounts
By Stephen J. Dunn |
U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the ...
Read More Reporting Horrors of Foreign Mutual Funds (“PFICs”)
By Stephen J. Dunn |
U.S.-based mutual funds annually issue to each of their shareholders a Form 1099 reporting the shareholder’s share of interest, dividends, ...
Read More You May Only Need to File Delinquent FBARs
By Stephen J. Dunn |
Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts. Those obligations include ...
Read More Beneficial Ownership, Income Tax, and FBARs
By Stephen J. Dunn |
For U.S. income tax purposes, ownership of property means beneficial ownership. Only the beneficial owner of property is required to ...
Read More U.S. Persons’ Reporting Obligations Regarding Foreign Financial Assets
By Stephen J. Dunn |
The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets. The reporting ...
Read More Passive Foreign Investment Companies: U.S. Clients Should Consider Tax Compliance
By Stephen J. Dunn |
Foreign mutual funds, known as passive foreign investment companies or “PFICs,” pose significant compliance burdens for U.S. taxpayers. Click here for the ...
Read More The Use of John Doe Summonses in Identifying U.S. Persons’ Accounts
By Stephen J. Dunn |
John Doe summonses are an expeditious weapon available to the U.S. government in identifying U.S. taxpayers’ foreign financial accounts. Click here for ...
Read More Beneficial Ownership of a Foreign Financial Account
By Stephen J. Dunn |
Beneficial ownership is a pivotal yet elusive concept in the foreign financial accounts arena. Click here for the full article. Other posts ...
Read More Is It A Foreign Account?
By Stephen J. Dunn |
The Bank Secrecy Act, 31 USC 5314, authorizes the U.S. Treasury to enact regulations concerning transactions by a United States ...
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