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Foreign Trusts Tax Returns

Bilzin Sumberg

Fighting a Three Headed Dog and Tax Classifications of Foreign Trusts

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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

Freeman Law

Is a Stiftung a Foreign Trust? Form 3520 Penalties?

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In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties.  The case arose in the context of a Liechtenstein...more

Freeman Law

How Do I Know if I Have an IRS Form 3520/3520-A Filing Obligation?

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Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may have to file a Form 3520, a Form...more

Freeman Law

The IRS’s Renewed Focus on Abusive Trust Arrangements

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Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors.  Generally, there is nothing nefarious about these types of arrangements.  Rather,...more

Freeman Law

Failure to Report Foreign Trust Results in 35% Penalty Against the Owner/Beneficiary

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The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more

Bilzin Sumberg

Emily S. Wilson et al. v. United States: Playing Battleship with the Internal Revenue Service

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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

Bilzin Sumberg

IRS Expands E-Signature Policy to Include Gift and Estate Tax Returns and Foreign Trust Reporting Forms

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On August 28, the IRS announced that it would temporarily accept e-signatures on certain forms. Included among that initial list of forms was Form 8832, Entity Classification Election (commonly known as a “check-the-box”...more

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