Foreign Accounts Compliance
New Law Extends U.S. Government’s Reach to Foreign Financial Accounts
By Stephen J. Dunn |
The United States taxes its citizens and residents (“U.S. persons”) on their worldwide income. U.S. persons commonly used foreign financial ...
Read More 
Delinquent International Information Return Submission Procedures vs. Streamlined Procedures for Foreign Accounts Compliance
By Stephen J. Dunn |
An individual can become compliant with United States laws concerning foreign income, accounts, and entities by means of the Internal ...
Read More 
Hunter Biden’s Tax Returns
By Stephen J. Dunn |
Hunter Biden is alleged to have received millions of dollars in income from sources in Russia, the Ukraine, and China; ...
Read More 
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 ...
Read More 
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. ...
Read More
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 ...
Read More 
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 ...
Read More 
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 ...
Read More 
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 ...
Read More 
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 ...
Read More