The IRS has been closely examining the accurate and timely reporting of foreign gifts and distributions to and from foreign trusts. As part of this effort, the Large Business and International ...
In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties. The case arose in the ...
The IRS continues to aggressively enforce certain foreign information return obligations. In many cases, these enforcement efforts are automatic—that is, the agency simply imposes the applicable ...
New Proposed Guidance From the IRS on Foreign Trust Transactions and Large Gifts From Non-US Persons
On May 8, the IRS issued proposed regulations addressing matters related to foreign trusts and large gifts received from "nonresident aliens" (NRAs) by a U.S. person. See REG-124850-08 (proposed ...
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