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Stephen J. Dunn

Stephen Dunn



Sep 21, 2021
Dunn: Internal Revenue Code Section 965 and the Streamlined Procedures
Internal Revenue Code § 965, as added by the Tax Cut and Jobs Act of 2017, requires a controlled foreign corporation ("CFC") to include in its Subpart F income.


Jul 6, 2021
Advantageous Abandonment of a US Green Card
If you have the status of lawful permanent resident of the U.S. and you reside in the U.K. and you intend to abandon your green card, you should know that by planning may enable you to avoid substantial U.S. income tax upon expatriating.


Mar 29, 2021
New Law Extends U.S. Government's Reach to Americans' Foreign Accounts
The United States taxes its citizens and residents (U.S. persons) on their worldwide income. U.S. persons commonly used foreign financial accounts to evade U.S. income tax. Unlike U.S. financial institutions, foreign financial institutions do not report to the U.S. Internal...


Jan 18, 2021
Delinquent International Information Return vs. Streamlined Procedures for Foreign Accounts
An individual can become compliant with United States laws concerning foreign income, accounts and entities by means of the Internal Revenue Service's Streamlined Procedures or its Delinquent International Information Return Submission Procedures ("DIIRSP").


Jan 7, 2021
Expenses Paid With CARES Act Loan Proceeds Are Now Tax-Deductible
The Coronavirus Aid, Relief, and Economic Security Act of 2020 (CARES Act) provided for federally guaranteed loans to small businesses. The loans are forgiven to the extent used for qualifying purposes, including employee compensation, continuation of group healthcare...


Dec 31, 2020
Reporting Foreign Income and Interests to the IRS
Hunter Biden is alleged to have received millions of dollars in income from sources in Russia, the Ukraine, and China; to have failed to report some or all of the income on a U.S. income tax return; and to have received the income through foreign shell corporations used to...


Nov 20, 2020
Don't Try to Outsmart Govt Estate and Gift Tax
For most people, gifting property in anticipation of reduction of the federal estate and gift tax exclusion amount is not a good idea.


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

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