U.S. taxation of foreign estates, trusts and beneficiaries /

" ... gives a survey of the history of trusts, explains in detail the U.S. federal income, estate, and gift taxation of foreign trusts and estates and their grantors and beneficiaries. The Portfolio also provides a secondary discussion of select U.S. state taxation analogues. An entity is subje...

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Bibliographic Details
Main Author: Heimos, Michael A., 1969-
Corporate Author: Tax Management Inc
Other Authors: Zaritsky, Howard M., 1949-, Rosen, Howard D
Format: Online
Language:English
Published: Arlington, VA : Tax Management Inc., ©2008-
Series:Tax management portfolios ; 6500
Subjects:
Online Access:https://www.bloomberglaw.com/product/tax/citation/tm%206500
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Table of Contents:
  • Detailed analysis. Introduction and general history of trusts
  • Foreign trusts and U.S. taxation: a brief history
  • What constitutes a foreign trust ([section] 7701)
  • Outbound foreign trusts ([section] 679 and [section] 684)
  • Inbound transfers and taxation of U.S. income of nongrantor foreign trusts
  • U.S. wealth transfer taxes on foreign transfers to foreign trusts
  • Reporting requirements for foreign trusts
  • The situs of foreign trusts
  • Drafting, executing, and administering foreign trusts
  • Special planning uses of foreign trusts
  • Investments by foreign trusts
  • Foreign estates
  • Collection and enforcement
  • Working papers