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US Taxation on Foreign Trusts

US Taxation on Foreign Trusts

By Charles M. Bruce


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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.

  • Publish Date 03/01/2000
    Publish Frequency As Needed
    Product Line Kluwer Law International
    ISBN 9789041193827
    SKU 10058798-0001
    Table of Contents
      Brief History of Trusts
      Definition of Trust and Foreign Trust
      Different Types of Trusts for Tax Purposes
      Some Common Types of Foreign Trust
      Examples of Uses
      Taxation of Trusts: Overview
      Distributable Net Income
      Nongrantor Trusts: Complex
      Throwback Rules
      Interest Charge
      Grantor Trusts
      Special Rules Applicable to Foreign Trusts
      Tax Reform Act of 1976
      Small Business Job Protection Act of 1996
      Effective Dates
      Transition Rules
      Forthcoming Regulations, etc
      Protection of Assets Trusts
      Tax Treatment of Underlying Entities and Insurance Products
      Reporting Rules and Penalties
      Appointment of U.S. Agent
      Compliance Issues
      Collection and Enforcement
      Trusts in Treaties
      Large Gifts Received by U.S. Persons
      Individuals Immigrating To and Expatriating From the U.S.
      What Happens When the Grantor Dies

      A. Statutory Provisions
      B. Forms and Instructions
      C. Excerpts from IRS Training Materials