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Credit Suisse Former Clients Likely To Come Under Heightened IRS Scrutiny For Credit Suisse's Purported Continued Role In The Hiding And Failing To Report Offshore Accounts - Income Tax

On March 19th, 2023, UBS Group announced it had agreed to buy its beleaguered rival Credit Suisse. However, mere days later a Senate Finance report has revealed that despite Credit Suisse's 2014...
Senate Finance Committee Revenue Service Us Department Of Justice Credit Suisse Bank Leumi Disclosure Program
Source: mondaq.com

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What Makes a Trust a "Foreign" Trust? | Bilzin Sumberg

To embed, copy and paste the code into your website or blog: In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal tax purposes. What, then, makes a trust a "foreign" trust? The Internal Revenue Code unhelpfully provides that a foreign trust is any trust that is not a domestic trust. 1 Accordingly, whether a trust is a foreign ...
United States Bilzin Sumberg Court Test Internal Revenue Code Control Test Fincen Form

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