Stephen Dunn



Dec 26, 2019
Many such “accidental Americans” seek to renounce their U.S. citizenship. 


Nov 26, 2019
After the end of a long-term marriage, you should not rush into remarriage. Certainly you should seek competent legal counsel before remarrying.


Oct 28, 2019
The United States taxes its citizens and residents on their worldwide income. It does this by means of the Internal Revenue Code.


Sep 3, 2019
The first thing a taxpayer should do who is out of compliance with United States laws concerning foreign financial accounts is immediately file delinquent FinCEN Forms 114, Report of Foreign Bank and Financial Accounts, (“FBARs”), or amended FBARs for the preceding six years.


Jul 25, 2019
The Internal Revenue Service ended its Offshore Voluntary Disclosure Program (“OVDP”) effective September 28, 2018.  Since then the IRS has made its Voluntary Disclosure Practice (“VDP”) available to willfully-noncompliant taxpayers. 


May 16, 2019
The IRS imposes severe penalties for failure to comply with U.S. laws concerning foreign financial accounts.  The IRS tends not to impose the penalties where the taxpayer voluntarily complies with the law without the IRS bringing the delinquency to the taxpayer’s attention. 


Apr 22, 2019
The IRS cancelled its Offshore Voluntary Disclosure Program (“OVDP”). This is a positive development. OVDP was by far the most onerous, costly foreign accounts voluntary disclosure program.


Jan 9, 2019
To qualify for the Streamlined Procedures, an individual must have underreported tax on a U.S. income tax return filed in the last three years, and such noncompliance must have been nonwillful.

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