News & Analysis as of

Tax Liability 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

Gray Reed

IRS Concedes Yet Another Form 3520 Related Penalty Case

Gray Reed on

United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws.  For example, buried within the Code are reporting obligations...more

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

Allen Barron, Inc. on

Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Bilzin Sumberg

Fighting a Three Headed Dog and Tax Classifications of Foreign Trusts

Bilzin Sumberg on

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

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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