Stephen Dunn



Oct 8, 2018
A U.S. taxpayer whose interest in a closely-held foreign corporation meets a specified threshold must file Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, with his U.S. income tax return reporting his interest in the foreign corporation.


Aug 31, 2018
Surely Manafort’s filing of amended income tax returns would have produced no worse circumstances for Manafort than those in which he now finds himself.


Aug 1, 2018
The Internal Revenue Service’s Streamlined Procedures are a popular means for U.S. taxpayers to come into compliance with U.S. laws concerning foreign financial accounts.


Jul 26, 2018
U.S. v. Colliot (W.D. Tex. Case No. 1:16-cv-01281) is an action to reduce to judgment civil penalties allegedly assessed for failure to report foreign financial accounts on Reports of Foreign Bank and Financial Accounts (“FBARs”).


Jul 12, 2018
An organizer is a questionnaire which an accountant sends to a client to provide information needed to prepare the client’s tax returns. The problem is that there is no accountant-client privilege guarding this information.


Jul 9, 2018
In February, 2018 the United States implemented a program of denying passports to Americans owing at least $51,000 in delinquent taxes, or revoking such individuals’ passports.


Jun 27, 2018
The settlements which MSU is paying the gymnasts, an average of $1.28 million per victim (before fees and costs), are free of federal income tax to the victims.


Apr 23, 2018
The Federal obstruction of justice statute is hopelessly flawed. A more precisely-drawn statute, such as for witness tampering or destruction of evidence, would make more sense.

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