CFC/PFIC Attribution Through Foreign Trusts
Attribution Rules, Tax Implications, and Reporting (Under New Proposed Regulations)
Recording of a 110-minute CPE webinar with Q&A
This webinar will explain the rules under which the ownership of foreign corporations owned by foreign nongrantor trusts may be attributed to the US beneficiaries of those trusts, as well as the potential tax payment and reporting obligations of those US beneficiaries. In particular, the panel will provide a timely analysis of the newly-released proposed Treasury regulations, Transactions With Foreign Trusts and Information Reporting on Transactions With Foreign Trusts and Large Foreign Gifts (REG-124850-08). These complex rules will be illustrated by case studies. The panel will also offer concrete advice on avoiding pitfalls and planning proactively to optimize taxation and reporting.
Outline
- Foreign corporation anti-deferral regimes (CFCs and PFICs) – an overview
- Foreign trust anti-deferral regime (throwback tax) – an overview
- CFC/PFIC attribution through foreign nongrantor trusts – taxation and reporting
- Proposed regulations on foreign trust reporting
- Case studies
Benefits
The panel will cover these and other critical issues:
- Determining CFC/PFIC direct, indirect and constructive ownership in general
- Determining CFC/PFIC attribution to US beneficiaries of foreign nongrantor trusts
- Determining US beneficiaries’ tax payment and reporting obligations when they are attributed CFC/PFIC interests through foreign nongrantor trusts
- Identifying legal uncertainties and proactively optimizing clients’ US tax and reporting position
- Tax compliance issues
Faculty
Lawrence M. Lipoff, CPA, TEP
Director
CohnReznick
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private... | Read More
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value. Mr. Lipoff is a frequent lecturer and author of articles published through professional forums on topics including domestic and international - estate planning and fiduciary income taxation including constructive attribution rules for foreign trusts, Forms 3520 & 3520-A, Graegin Loans, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private investment fund principals, preferred freeze partnerships, and private placement life insurance.
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Shudan Zhou
Partner
Norton Rose Fulbright US
Ms. Zhou focuses her practice on counseling high net worth individuals, trustees, and financial institutions on the... | Read More
Ms. Zhou focuses her practice on counseling high net worth individuals, trustees, and financial institutions on the US tax implications of wealth transfer strategies, with an emphasis on international income and estate tax planning. She has substantial experience advising clients on all aspects of FATCA and CRS as well as various withholding tax and disclosure regimes. Ms. Zhou frequently counsels clients on the US tax consequences of expatriation from and immigration to the United States, and of US inbound and outbound investment structures. She also advises on the creation, administration and governance of offshore trust structures.
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