• videocam Live Webinar with Live Q&A
  • calendar_month @ 1:00 p.m. ET./10:00 a.m. PT
  • card_travel Estate Planning
  • schedule 60 minutes

U.S. Taxation of Foreign Trusts: Grantor Trust Status, Gift and Estate Tax Treatment, Reporting Requirements, Planning

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About the Course

Introduction

This CLE/CPE course will provide estate planners and tax counsel comprehensive guidance on the U.S. taxation of foreign trusts. The panel will discuss key provisions of the Internal Revenue Code applicable to foreign trusts, the reporting regime for U.S. taxpayers' ownership of foreign trust assets, gift and estate tax treatment, and Form 3520 and other foreign information reporting requirements.

Description

U.S. owners and beneficiaries of foreign trusts are subject to complex tax rules and reporting obligations that are different from those applicable to domestic trusts. Tax and estate planners must recognize the variety of tax issues associated with foreign trusts with U.S. owners or beneficiaries.

Tax and estate planners must determine under U.S. tax rules whether an arrangement is a trust, the residency of the trust as foreign or domestic, and the characterization of the trust. Determination of a trust's residency and characterization will determine the potential income and estate tax impact to the beneficiaries, including potential attribution of ownership entities owned by the trust and complex information reporting obligations.

Tax and estate planning advisers must establish strategies to ensure that U.S. owners and beneficiaries of foreign trusts avoid any unintended tax liability on interests of foreign trusts, including such trusts' interest in foreign partnerships or corporations while avoiding foreign anti-deferral rules.

Listen as our panel discusses key provisions of the Internal Revenue Code applicable to foreign trusts, the reporting regime for U.S. taxpayers' ownership of foreign trust assets, gift and estate tax treatment, Form 3520, and other key items regarding the taxation of foreign trusts.

Credit Information

Date + Time

  • event

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Issues of foreign trusts with U.S. beneficiaries in estate planning

II. Determining tax residency and applicable rules

III. Understanding tax rules and reporting obligations of foreign trusts for U.S. estates and taxpayers

IV. Foreign grantor trust vs. foreign non-grantor trust

V. Obtaining a tax-free step-up in basis

VI. Applicability of foreign anti-deferral rules and methods to avoid them

The panel will discuss these and other key issues:

  • What are the filing requirements for the U.S. beneficiary of a foreign trust?
  • Avoiding pitfalls of complex tax rules and reporting obligations
  • Understanding residency rules and the use of domestication to benefit the estate
  • What "reportable events" trigger a Form 3520 filing requirement?
  • What is the overlap between Form 3520 and other foreign information reporting requirements?
  • What are the penalties and relief provisions for failing to file necessary forms?
  • Effective techniques to avoid foreign anti-deferral rules
  • Best practices for counsel regarding the taxation of foreign trusts