News & Analysis as of

International Tax Issues Internal Revenue Code (IRC) Foreign Trusts

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Freeman Law

The IRS’s Renewed Focus on Abusive Trust Arrangements

Freeman Law on

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

Freeman Law on

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

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