Foreign Accounts Compliance
U.S. Tax Compliance Concerning Foreign Income, Accounts, and Entities
By Stephen J. Dunn |
United States citizens and residents (“U.S. persons”) need to comply with two U.S. statutory schemes concerning foreign income, accounts, and ...
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Taxpayer Wins FBAR Penalty Case
By Stephen J. Dunn |
In 2012, Alexandru Bittner filed FinCEN Forms 114, Report of Foreign Bank and Financial Accounts, (“FBARs”) for the years 2007-2011. ...
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Recent Case Underscores Importance of Delinquent International Information Return Submission Procedures
By Stephen J. Dunn |
On February 12, 2018, the IRS assessed $160,000 in penalties against Vivian Ruesch under Internal Revenue Code Section 6038(b) for ...
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Forms 3520 and 3520-A: What You Need to Know
By Stephen J. Dunn |
If you own an interest in a foreign trust, you may be required to file Form 3520, Annual Return To ...
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U.S. Income Taxation of U.K. SIPPs and ISAs
By Stephen J. Dunn |
Note: This is the third of three articles on United States income taxation of British Self-Invested Pension Plans (“SIPPs”) and ...
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Illusory Revenue Procedure 2020-17
By Stephen J. Dunn |
A self-invested personal pension (“SIPP”) is a highly advantageous personal pension plan available under United Kingdom law. Separate articles consider ...
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U.S. Income Taxation of Contributions to SIPPs and ISAs
By Stephen J. Dunn |
Note: This is the second of three articles on United States income taxation of Self-Invested Pension Plans (“SIPPs”) and Individual ...
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What Are U.K. SIPPs and ISAs, and How Are they Reported for U.S. Tax Purposes?
By Stephen J. Dunn |
Note: This is the first of three articles on United States Income Taxation of British Self-Invested Pension Plans (“SIPPs”) and ...
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Accidental Americans
By Stephen J. Dunn |
Hans was born in the United States 43 years ago. When Hans was 6 years old his parents moved back ...
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Beware Form 3520-A
By Stephen J. Dunn |
A U.S. personwho is a beneficiary of a foreign grantor trust must report the trust to the Internal Revenue Service ...
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