United States Taxation of Foreign Trusts

By: Charles M. Bruce

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Hardcover | 1 March 2000

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Hardcover
402 Pages

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23.39 x 15.6 x 2.24

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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.

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Non-Fiction Accounting & Finance Finance Investment & Securities Law Laws of Specific Jurisdictions Taxation & Duties Law Public Accounting in Finance Tax & Taxation Equity & Trusts International Law

Frontpiece
Preface
Introduction	p. 1
Brief History of Trusts	p. 6
Definitions of Trust and Foreign Trust	p. 21
Different Types of Trusts for Tax Purposes; Some Common Types of Foreign Trust; Examples of Uses	p. 43
Taxation of Trusts: Overview; Distributable Net Income	p. 49
Nongrantor Trusts: Simple	p. 67
Nongrantor Trusts: Complex; Throwback Rules; Interest Charge	p. 70
Grantor Trusts	p. 92
Special Rules Applicable to Foreign Trusts	p. 116
Tax Reform Act of 1976	p. 168
Small Business Job Protection Act of 1996	p. 190
Effective Dates; Transition Rules; Forthcoming Regulations, Etc.	p. 209
Protection of Assets Trusts	p. 214
Tax Treatment of Underlying Entities and Insurance Products	p. 223
Reporting Rules And Penalties; Appointment Of U.S. Agent	p. 245
Reporting Forms	p. 259
Compliance Issues; Collection and Enforcement; Trusts in Treaties	p. 288
Large Gifts Received by U.S. Persons; Individuals Immigrating to and Expatriating from the U.S.; What Happens When the Grantor Dies	p. 299
Index	p. 314
App. A: Forms And Instructions	p. 318
Table of Contents provided by Blackwell. All Rights Reserved.

United States Taxation of Foreign Trusts

At a Glance

Hardcover

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