Stephen Dunn

Sep 30, 2020
United States citizens and residents ("U.S. persons") need to comply with two U.S. statutory schemes concerning foreign income, accounts, and entities.

Aug 10, 2020
COVID Tax Tip 2020-77, recently issued by the Internal Revenue Service, gives reasons why taxpayers should file a 2019 income tax return.

Jul 17, 2020
The IRS has traditionally shown restraint in imposing penalties upon taxpayers who correct their noncompliance voluntarily, without the IRS prompting them about it.

Jun 29, 2020
The Explanation of Changes to the taxpayer’s amended U.S. income tax return should explain the taxpayer’s reasonable cause for failing to timely file the information returns, and that the taxpayer is proceeding under the Delinquent International Information Return Submission Procedures.

Jun 11, 2020
The IRS may grant relief from penalties for failure to timely file Forms 3520 or 3520-A is due to reasonable cause and not willful neglect.

May 26, 2020
In ordinary times, an offer in compromise is rarely in a taxpayer’s best interests. Most offers in compromise are ultimately not accepted by the IRS.

May 15, 2020
A SIPP is a highly advantageous personal retirement saving scheme available under U.K. tax law.

May 11, 2020
Financial abuse of elders is a serious problem. I have seen much of it in my career.

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