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Due to concerns about the potential use of foreign trusts and gifts as a means to access the proceeds of unreported income, the Internal Revenue Code (the "Code") and related regulations...
On May 8, the IRS published proposed regulations that provide guidance regarding the information reporting of transactions with foreign trusts, the receipt of large foreign gifts and...
It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign...
U.S. citizens and residents who have received gifts (including bequests) exceeding certain thresholds from foreign persons must generally report such gifts to the IRS. Recipients of...
The IRS has been busy in the international realm triggering several court decisions that should get the attention of all taxpayers with any level of global reach.