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The US tax and reporting rules applicable to foreign trusts -
principally embodied as Subchapter J of the Internal Revenue Code
of 1986, as amended - are notoriously complex. Now, with this
volume, anyone who has to deal with these rules can find their use
and meaning clearly explained, and proceed confidently to the best
outcome in any situation where they apply. This guide covers all
the following topics in detail: regular nongrantor (or
accumulation) trusts of both the "simple" variety and the "complex"
type with its challenging "throwback" rules and interest charge on
accumulation distributions; the circumstances under which certain
foreign trusts, such as section 672(f) (barring the application of
the normal grantor trust rules to certain foreign trusts), section
643(h) (relating to distributions by certain foreign trusts through
nominees), and section 643(i) (relating to loans from foreign
trusts); reporting and penalty provisions and the accompanying IRS
forms; and special issues, such as those surrounding incoming
immigrants and outgoing expatriates. The book provides modified
versions of the principal IRS forms (3520, 3520-A, 4970, 1040NR,
and 1041) that are commonly filed for foreign trusts. These
modifications, which scrupulously follow all applicable IRS rules,
are much easier to use than the actual forms for the purpose of
foreign trusts. Numerous examples throughout the book clarify the
valid procedures and alternatives available at every point, a
feature particularly useful in applying provisions that still await
settled regulation and case law. Compliance issues that may arise
on IRS audit are also examined. Professionals and advisors in law,
tax, accounting, banking, and securities; settlers and
beneficiaries; and students and academics both within and outside
the United States should find this an informative and useful
volume.
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Nicola Davies
Hardcover
R457
Discovery Miles 4 570
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