United States taxation of foreign trusts
The US tax and reporting rules applicable to foreign trusts--principally embodied as Subchapter J of the Internal Revenue Code of 1986, As amended--are notoriously complex. Now, with this convenient and practical volume, anyone who must deal with these rules will find their use and meaning clearly explained, and proceed confidently To The best outcome in any situation where they apply. United States Taxation of Foreign Trusts covers the following topics in detail: Regular nongrantor (or accumulation) trusts of both the 'simple' variety And The 'complex' type with its challenging 'throwback' rules and interest charge on accumulation distributions; The circumstances under which certain foreign trusts; The special rules formulated solely for foreign trusts such as section 672(f) (barring the application of the normal grantor trust rules to certain foreign trusts), section 643(h) (relating to distributions by certain foreign trusts through nominees), and section 643(i) (relating to loans from foreign trusts); Reporting and penalty provisions And The accompanying IRS forms; and Special issues, such as those surrounding incoming immigrants and outgoing expatriates. Numerous examples throughout the book clarify the valid procedures and alternatives available at every point, a feature especially valuable in applying provisions that still await settled regulation and case law. Compliance issues that may arise on IRS audit are also examined. Professionals and advisors in law, tax, accounting, banking, and securities; settlors and beneficiaries; and students and academics both within and outside the United States will benefit substantially from this highly informative and very useful volume.
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Some Common Types of Foreign Trust
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accumulation distribution allocable AMT purposes apply assets trust attach capital gains charitable Code computation corpus court created decedent determined distributed currently domestic trust election Enter the amount estate or trust example fair market value fiduciary file Form foreign corporation Foreign Grantor Trust foreign nongrantor trust foreign person foreign trust gift or bequest gift tax grantor trust rules gratuitous transfer gross income identification number income tax individual instructions interest charge investment lf the estate loss nonresident alien ordinary income paid partnership payments penalty PFlC portion protection of assets received regular tax purposes regulations resident Schedule K-1 section 679 settlor shareholder simple trust Small Business Small Business Act Subtract line taxable income taxation taxpayer throwback transferor Treasury treated trust instrument U.S. agent U.S. beneficiary U.S. grantor U.S. owner U.S. person U.S. tax undistributed net income