Stephen Dunn



Aug 7, 2019
People create a revocable trust, and transfer their assets to it, to avoid probate court proceedings at their death. When spouses create such a trust, for Medicaid nursing home coverage purposes each of them is deemed to own the assets held in the trust.


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.


Jan 4, 2019
The Internal Revenue Code requires U.S. taxpayers whose interests in foreign financial accounts exceed certain thresholds to report those interests in foreign financial assets on Form 8938, Report of Specified Foreign Financial Assets, filed with their annual U.S. income tax return.


Dec 26, 2018
Every U.S. person who has a financial interest in, or signature authority over, foreign financial accounts with an aggregate balance exceeding $10,000 at any time during a calendar year must report their interests in foreign accounts on an FBAR for that year.


Nov 12, 2018
Clearly taxpayers should not gratuitously file international information returns. For a taxpayer who does have delinquent international information returns, the prospect of seeking abatement of penalties for reasonable cause may offer the best hope.

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