An analysis of new reporting requirements for foreign trusts

Article Abstract:

The authors discuss the foreign trust tax compliance provisions of the Small Business Job Protection Act of 1996. Topics include the Act's definitions of domestic and foreign trusts, and the reporting of transfers to foreign trusts by US persons.

International, Small business, Information returns

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New rules to ensure better reporting by foreign trusts

Article Abstract:

Foreign trusts have been made less attractive from a US taxation perspective after changes in substantive and reporting provisions by the Small Business Job Protection Act of 1996. The IRC section 1491 35% excise tax extension is one of three major substantive deterrents of the new scheme. New stringent reporting requirements subject grantors and beneficiaries to substantial penalties if filings are untimely or contain inadequate information.

Foreign investments

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An analysis of transfer taxes on nonresident aliens

Article Abstract:

The authors present an overview of the US transfer taxation of nonresident aliens and how it differs from the taxation of US citizens and resident aliens. Estate, gift, and generation-skipping tax law and planning issues and the influence of treaties are discussed. Tables indicating status differences and tax treaties are included.

Tax Law, Public Finance Activities, Personal Tax Planning, Personal finance, Transfer taxes, Non-resident aliens, Nonresident aliens

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