Who Must File. Generally, foreign trusts have an obligation to file a Form 3520-A with the IRS if the trust has a U.S. person who falls under the grantor trust rules. Because foreign trusts are ...

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 ...

Notwithstanding the Proposed Regulations, the reporting requirements for a U.S. person’s involvement with a foreign trust or receipt of foreign gifts or bequests are cumbersome and complex.

In 2024, the U.S. Treasury, issued long overdue regulations on foreign trust adding additional administrative reporting requirements, burdens, and qualifications on foreign trusts, highlighting ...

IRS seeks to bolster foreign trust, gift transactions rules By Tobias Salinger September 03, 2024, 2:43 p.m. EDT 3 Min Read ...

The complaint alleges that the IRS revoked its 2019 decision to treat WCF as a foreign non-grantor trust “without explanation” and proceeded to pull the estate out of the OVDP and commenced ...