Foreign Accounts Compliance

In the recent case of Farhy v. Commissioner, the Internal Revenue Service assessed penalties against Alon Farhy for failing to ...

Internal Revenue Code (“IRC”) Section 403(b) annuities, Section 401(k) plans, and Section 408 individual retirement arrangements, whether individual retirement accounts ...

On November 2 the Supreme Court held oral arguments in Bittner,[1] on whether the failure to timely file a Financial ...

In United States v. Bittner, the U.S. Court of Appeals for the Fifth Circuit held that the $10,000 penalty for ...

If an individual (“principal”) while mentally competent executes a durable power of attorney, then his agent (also-called “attorney-in-fact”) acting under ...

Renunciation of United States citizenship or abandonment of United States lawful permanent resident (“green card”) status is a major event ...

Many United Kingdom citizens retire in the United States after working in the United Kingdom.  Such individuals’ interests in United ...

Immigration to the United States continues at a strong pace.  The people coming over tend to be members of the ...

Internal Revenue Code § 965, as added by the Tax Cut and Jobs Act of 2017, requires a controlled foreign ...

If you have the status of lawful permanent resident of the United States (i.e., you are a “green card” holder), ...

The United States taxes its citizens and residents (“U.S. persons”) on their worldwide income.  U.S. persons commonly used foreign financial ...

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

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

The first thing a taxpayer should do who is out of compliance with United States laws concerning foreign financial accounts ...

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

At the American Bar Association Taxation Section’s annual meeting in Washington, D.C., in May, 2019, IRS representatives said the IRS ...

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

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires U.S. taxpayers to ...

A U.S. taxpayer whose interest in a foreign partnership meets a specified threshold must file with his U.S. income tax ...

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

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires the filing of ...

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

U.S. persons are required to report to the United States government concerning foreign financial accounts. A “U.S. person” is a ...

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

U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the ...

U.S.-based mutual funds annually issue to each of their shareholders a Form 1099 reporting the shareholder’s share of interest, dividends, ...

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include ...

For U.S. income tax purposes, ownership of property means beneficial ownership.  Only the beneficial owner of property is required to ...

The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets.  The reporting ...

Foreign mutual funds, known as passive foreign investment companies or “PFICs,” pose significant compliance burdens for U.S. taxpayers.  Click here for the ...

John Doe summonses are an expeditious weapon available to the U.S. government in identifying U.S. taxpayers’ foreign financial accounts.  Click here for ...

Beneficial ownership is a pivotal yet elusive concept in the foreign financial accounts arena.  Click here for the full article. Other posts ...

The Bank Secrecy Act, 31 USC 5314, authorizes the U.S. Treasury to enact regulations concerning transactions by a United States ...