Foreign Accounts Compliance

Michigan Durable Powers Of Attorney

An elderly woman living alone suffers a stroke, and falls.  Later, at a rehabilitation facility, the woman falls again, this ...
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Expatriation From The United States

Renunciation of United States citizenship or abandonment of United States lawful permanent resident (“green card”) status is a major event ...
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United States Income Taxation Of United Kingdom-Based Pension Plans

Many United Kingdom citizens retire in the United States after working in the United Kingdom.  Such individuals’ interests in United ...
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Foreign Accounts Compliance Update

Immigration to the United States continues at a strong pace.  The people coming over tend to be members of the ...
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Internal Revenue Code § 965 and the Streamlined Procedures

Internal Revenue Code § 965, as added by the Tax Cut and Jobs Act of 2017, requires a controlled foreign ...
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Advantageous Abandonment of a U.S. Green Card

If you have the status of lawful permanent resident of the United States (i.e., you are a “green card” holder), ...
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New Law Expands U.S. Government’s Discovery of Americans’ Foreign Accounts

The United States taxes its citizens and residents (“U.S. persons”) on their worldwide income.  U.S. persons commonly used foreign financial ...
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Americans’ Interests in Foreign Accounts Reportable on Form 8938

The United States taxes its citizens and residents on their worldwide income.  Accordingly, the U.S. Internal Revenue Code requires U.S. ...
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The FBAR Filing Requirement

The United States taxes its citizens and residents on their worldwide income.  To evade U.S. income tax, U.S. taxpayers were ...
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Foreign Accounts Compliance Update

The first thing a taxpayer should do who is out of compliance with United States laws concerning foreign financial accounts ...
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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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Compliance Required of U.S. Persons Concerning Foreign Financial Accounts

U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the ...
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Reporting Horrors of Foreign Mutual Funds (“PFICs”)

U.S.-based mutual funds annually issue to each of their shareholders a Form 1099 reporting the shareholder’s share of interest, dividends, ...
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You May Only Need to File Delinquent FBARs

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include ...
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Beneficial Ownership, Income Tax, and FBARs

For U.S. income tax purposes, ownership of property means beneficial ownership.  Only the beneficial owner of property is required to ...
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U.S. Persons’ Reporting Obligations Regarding Foreign Financial Assets

The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets.  The reporting ...
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Passive Foreign Investment Companies: U.S. Clients Should Consider Tax Compliance

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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The Use of John Doe Summonses in Identifying U.S. Persons’ Accounts

John Doe summonses are an expeditious weapon available to the U.S. government in identifying U.S. taxpayers’ foreign financial accounts.  Click here for ...
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Beneficial Ownership of a Foreign Financial Account

Beneficial ownership is a pivotal yet elusive concept in the foreign financial accounts arena.  Click here for the full article. Other posts ...
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Is It A Foreign Account?

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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