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Fundamentals of Foreign Trust Taxation on Distributions to U.S. Beneficiaries

Learn the fundamentals of foreign trust taxation while determining the requirements needed of U.

S. beneficiaries. The U.S. is one of the most sought jurisdictions for wealthy foreign families to immigrate for various reasons, seeking to expand their investments in real estate and other operating activities, educate their children, or merely for a better quality of life. In establishing a connection with the U.S. many of these families and individuals bring with them an offshore wealth structure or other non-U.S. assets not yet structured with the U.S. tax rules in mind. This topic will assist professionals servicing such clients in determining what are the U.S. tax implications and exposures to importing such structure or assets, the complexities of reporting such structure or assets to the U.S. tax authorities and how to provide the desired benefits of the structure efficiently within the confines of the U.S. tax system.

Runtime: 89 minutes
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Over 32 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

Determine U.S. vs. Foreign Trust Status

  • Discuss Complicated and Involved Scenarios

Determine Grantor vs. Non-Grantor Status

  • Discuss Involved Situations
    • Date of Death
    • Incapacity

Taxation of U.S. Beneficiaries

  • Discuss the Computation of Distributable Net Income Under the New Tax Law (2018 TCJA)
  • Appropriate and Best Uses of a 65-Day Election
  • When Best to Use a Check-The-Box Election for Underlying Foreign Companies
    • Before or After Date of Death
    • Incapacity
  • Explore Strategies for Minimizing the Impact of Accumulated Income (Undistributed Net Income)
  • Implications and Treatment of Using Foreign Trust Property
  • Domestication of Foreign Trusts

Review Reporting Requirements

  • Forms 3520 and 3520-A (Foreign Trust Reporting)
  • Form 8938 and Fincen 114 (Financial Asset and Account Reporting)
  • Form 4970 (Accumulated Income Tax and Penalty Calculation)
  • Other International Information Returns:
    • Form 5471 and 8865 (Controlled Foreign Corporations and Partnerships)
    • Form 8621 (Passive Foreign Investment Company)
    • Form 8832 (CheckTheBox Election)
    • Form 5472 (Re: Foreign Owned Single Member LLCs)

Discuss the Complexities of Civil Law Structures

  • Stiftungs
  • Usufructs
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Why Lorman?

Over 32 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

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on November 5, 2018.

Call 1-866-352-9540 for further credit information.

  • Arizona CLE 1.5
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, Inc. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 12.
     
  • MO CLE 1.8
     
  • This course qualifies for self-study CLE credit in Missouri.
     
  • MT CLE 1.5
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.5 CLE credits.
     
  • NH MCLE 1.5
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 90 Minutes.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.5
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
     
  • UT CLE 1.5
     
  • This program has been approved by the Utah State Board of Continuing Legal Education for 1.5 CLE hours.
     
  • VA CLE 1.5
     
  • This program has been approved by the Virginia Mandatory Continuing Legal Education Board for 1.5 CLE credit hours.
     
  • VT CLE 1.5
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hours of self-study CLE credit.
     
  • WA CLE 1.5
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.5 hours of A/V credit under the Law & Legal Procedure category.
     
  • WV MCLE 1.8
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.8 MCLE hours.
     

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

Virginia MCLE requirements do not allow approval for programs that do not include an audio or audiovisual component.

This program was previously offered as a live webinar. Virginia MCLE requirements do not allow approval for attendance at duplicate programs.

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

Audio & Reference Manual

  • AK CLE 1.25
     
  • Arizona CLE 1.25
     
  • CA MCLE
     
  • CT CLE 1.0
     
  • GA CLE 1.5
     
  • HI CLE
     
  • IL CLE 1.25
     
  • ME CLE 1.0
     
  • MT CLE
     
  • NJ CLE
     
  • NM CLE
     
  • NV CLE
     
  • UT CLE
     
  • VT CLE 1.25
     
  • WA CLE
     
  • WV MCLE
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

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

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Why Lorman?

Over 32 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

Jack Brister

Jack Brister

ERE LLP

  • Managing Partner of International Wealth Tax Advisors and has more than 25 years of experience
  • Specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures which include non-U.S. trusts, estates and civil law foundations that have a U.S. connection; and non-U.S. companies wanting to do business in the U.S.
  • Also specializes in non-U.S. persons investing in U.S. real property, and other U.S. assets, pre-immigration planning, U.S. expatriation matters, U.S. persons in receipt of gifts and inheritances from non-U.S. persons, non-U.S. account and asset reporting, offshore voluntary disclosures, FATCA registration and compliance (W-8BEN-E and Form 8966) and executives working and living abroad
  • Widely published, in addition to speaking at numerous international engagements; his article, "Foreign Trusts: The Capital Loss Debate", published by Trusts & Estates professional journal is still the only authority on the treatment of capital losses in computing foreign trust distributable net income
  • Can be contacted at 212-245-1142 or [email protected]
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Why Lorman?

Over 32 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.

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Product ID: 402916
Published 2018
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