IRS issues guidance on the treatment of a trust as foreign or domestic.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on March 1, 1997. The length of the article is 1823 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Trusts currently classified as domestic trusts that have foreign fiduciaries or were created outside the US may be considered foreign trusts under the revised definition of foreign trusts enacted as part of the Small Business Job Protection ACt of 1996. Classification as a foreign trust can trigger imposition of a 35% excise tax on built-in gain under IRC section 1491. IRS Notice 96-65 provides trusts with time to modify trust structure to meet the new domestic trust standards. Trusts may also elect to have the new trust laws applied retroactively.

Citation Details
Title: IRS issues guidance on the treatment of a trust as foreign or domestic.
Author: Arthur J. Dichter
Publication:The Tax Adviser (Magazine/Journal)
Date: March 1, 1997
Publisher: American Institute of CPA's
Volume: 28 Issue: n3 Page: 137(3)

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