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 non-filing, the 65-day 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.
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Why Lorman?
Over 34 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
What Distinguishes a Foreign Trust From a U.S. Trust?
- Court and Control Tests
- Safe Harbor Rules
- Substantial Decisions
- U.S. and Foreign CoTrustees
- 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
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Why Lorman?
Over 34 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 Course
This course was last revised on October 6, 2020.
Call 1-866-352-9540 for further credit information.
Enrolled Agents 2.0
- This program qualifies for 2.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 34 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
International Wealth Tax Advisors
- Managing member and founder of International Wealth Tax Advisors and has more than 30 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 34 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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