Description
Gain a better understanding on the differences in a foreign trust versus a United States trust and the reporting obligations for filing Form 3520.This topic will provide you with the fundamentals of U.S. foreign trust taxation the reporting requirements, the taxation of foreign trust distributions, how to compute foreign nongrantor trust distributable net income, the filing requirements, the penalties for late and nonfiling, the 65day election rule and the accumulated income rules (i.e., Throwback Tax). Additionally, you will be exposed to civil law wealth transfer structures that may also be treated as foreign trusts and other international information returns that may be required to be filed by beneficiaries and grantors of foreign trusts.
Date: 2020-10-06 Start Time: End Time:
Learning Objectives
What Distinguishes a Foreign Trust From a U.S. Trust?
• Court and Control Tests
• Safe Harbor Rules
• Substantial Decisions
• U.S. and Foreign Co-Trustees
• U.S. Trusts Treated as Foreign Trusts
How to Determine If a Trust Is a Grantor or Nongrantor Trust
When Does a Foreign Grantor Trust Become a Foreign Nongrantor Trust?
• Date of Death and Incapacity Issues
Taxation of U.S. Beneficiaries of Foreign Nongrantor Trusts
• Computing Distributable Net Income
• Expenses Allowed Under the Newly Enacted TCJA
• Distribution Ordering Rules
• Treatment of Net Capital Losses
• Accumulated Foreign Trust Income (Undistributed Net Income)
• Use of Foreign Trust Property
• 65-Day Distribution Election
Throwback Tax
• Rules
• Minimization Strategies
• Default Method
• Calculation
• Minimization Strategy
Tax Reporting Obligations
• Forms 3520 and Form 3520-A
• Other Related International Information Returns
Civil Law Wealth Transfer Mechanisms
Jack Brister-International Wealth Tax Advisors
