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Fundamentals of Foreign Trust Administration

Confidently handle your client's trust needs - get a thorough understanding of foreign trust administration.

Many U.S. taxpayers have or are considering establishing a foreign trust for privacy, asset protection or other purposes. In addition, many nonresident aliens establish foreign trusts before moving to the U.S. This topic will help you understand the different types of foreign trusts, how they are administered, the U.S. tax treatment of foreign trusts and their grantors and beneficiaries. It will also help you understand and comply with the FATCA rules and the new withholding tax applicable to foreign entities, including foreign trusts.

Runtime: 90 minutes
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview of Foreign Trust Issues

When Is a Trust a Foreign Trust

  • Foreign Governing Law

- Change in Situs and Governing Law Provisions

- Liechtenstein Siftungs, Swiss Foundations; Panama Foundations; Nevis Privacy Trusts

  • Foreign Trustees

Types of Foreign Trusts

  • Foreign Grantor Trusts
  • Foreign Nongrantor Trusts
  • Simple vs. Complex Trusts
  • Absolute vs. Discretionary Trusts
  • Privacy Trusts
  • Asset Protection Trust

Administration of Foreign Trusts

  • Corporate Trustees
  • Letters of Wishes
  • Protectors
  • U.S. Persons as Excluded Beneficiaries
  1. S. Tax Issues
    • Classification of Foreign Entities as Trusts or Corporations
    • Section 679

    - U.S. Grantor

    - Foreign Grantor and 5 Year Rule

    • Form 3520 and 3520-A
    • Accumulation Distributions
    • Nonqualifying Loans From the Foreign Trust
    • FATCA

    - Professional Trustees and Participating FFI Status

    - Other Trustees and NFFE Status

    - Reporting by Foreign Trust

    - Reporting by U.S. Beneficiary on Form 8938

    FinCEN Form 114 Reporting Requirements

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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Webinar

This program format does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

This program format does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Charles S. Kolstad

Charles S. Kolstad

Mitchell Silberberg & Knupp LLP

  • Tax partner in the Los Angeles office of Mitchell Silberberg & Knupp, LLP
  • Advises clients, accountants, and business managers throughout the U.S. on the income tax issues and reporting requirements that arise when individuals or companies conduct business outside of the U.S.
  • Advises U.S. clients on structuring foreign business activities with a view to minimizing their global effective tax rate on foreign income
  • Advised nonresident aliens planning on moving to the U.S. on the U.S. tax reporting requirements that apply once they become a U.S. tax resident, pre-immigration planning to step-up basis of assets, eliminate U.S. tax on previously earned income, etc.
  • Frequent speaker on income tax and international reporting requirements, and regularly prepares tax bulletins on topical issues
  • During his career, he has been a tax partner at both Coopers & Lybrand LLP and Ernst & Young LLP
  • J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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Product ID: 397801
Published 2016
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