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 ...
Read More 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 ...
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