The Continuing Saga of U.S. Tax Classification of Foreign Trusts and Related Penalty Issues -
In Greek mythology, Cerberus, a three-headed dog, was known as the guardian of the underworld. In more recent literature, a...more
One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more
As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS Form 3520 and IRS Form...more