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 trust is determined by analyzing whether the trust does or does not qualify as a domestic trust for ...
Source: jdsupra.com