Working with the complex tax rules governing inbound foreign trusts
Article Abstract:
The Small Business Job Protection Act of 1996 substantially limits US beneficiaries from receiving grantor trust status for tax purposes under trusts created by foreign persons. Beneficiaries of foreign nongrantor trusts will see their trust income taxed although the trust does not fall under US tax rules. Estate planners administering foreign trusts for US beneficiaries must continually review federal tax rules to ensure documents are properly drafted and maintained and tax consequences are minimized.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 1998
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Asset protection after Anderson: much ado about nothing?
Article Abstract:
The authors discuss the U.S. 9th Circuit Court of Appeals 1999 case FTC v. Affordable Media, LLC (the 'Anderson' case) which has been considered a threat to offshore asset protection trusts.. The authors point out specific facts in the case which distinguish it from other such trusts.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 1999
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New regs. address inbound grantor trusts with foreign grantors
Article Abstract:
The author discusses in detail IRS final and temporary regulations under IRC sections 672(f), 643(h), and 671 which provide guidance concerning the tax treatment of certain grantor trusts with foreign grantors.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 2000
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