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Constructive Attribution Rules for Foreign Trusts: Direct and Indirect Ownership, Reporting, PPLI, 953(d), Planning

A live 90-minute CLE/CPE video webinar with interactive Q&A

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Thursday, March 28, 2024

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, March 1, 2024

or call 1-800-926-7926

This CLE/CPE webinar will provide trusts and estates counsel and advisers guidance on the application of constructive attribution rules to foreign trusts, critical planning considerations, and pitfalls to avoid. The panel will provide a detailed analysis of constructive attribution rules for foreign trusts, pre-immigration trusts and domestication, beneficiary classes, ensuring compliance, and navigating Forms 3520, 3520-A, and 5471 and FBAR FinCEN Form 114. The panel will also go through case studies, issues stemming from the Corporate Transparency Act (CTA), potential IRS arguments to consider, and other key issues.

Description

U.S. owners and beneficiaries of foreign trusts are subject to complex tax rules and reporting obligations that are different from those applicable to domestic trusts. Tax and estate planners must recognize issues associated with foreign trusts with U.S. owners or beneficiaries and the application of constructive attribution and ownership rules regarding these foreign trusts.

Tax and estate planners must determine under U.S. tax rules whether an arrangement is a trust, the residency of the trust as foreign or domestic, and the characterization of the trust. For foreign trusts, the application of constructive attribution and ownership rules can potentially impact income and estate tax to the beneficiaries, including potential attribution of ownership entities owned by the trust and complex information reporting obligations.

Tax and estate planning advisers must establish strategies to ensure that U.S. owners and beneficiaries of foreign trusts avoid any unintended tax liability on interests of foreign trusts, including such trusts' interest in foreign partnerships or corporations while avoiding foreign anti-deferral rules.

Listen as our panel discusses the challenges of foreign trusts with U.S. beneficiaries, constructive attribution rules for foreign trusts, pre-immigration trusts and domestication, beneficiary classes, ensuring compliance, and navigating Forms 3520, 3520-A, and 5471 and FBAR FinCEN Form 114.

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Outline

  1. Understanding tax rules and reporting obligations of foreign trusts for U.S. estates and taxpayers
  2. Constructive attribution and ownership rules
  3. Pre-immigration trusts and Section 679 rules
  4. Issues stemming from the CTA
  5. Compliance forms: Forms 3520, 2520-A, and 5471; FBAR FinCEN Form 114
  6. Best practices for trusts and estates counsel

Benefits

The panel will review these and other key issues:

  • Navigating constructive attribution rules for foreign trusts
  • Avoiding pitfalls of complex tax rules and reporting obligations
  • Key issues stemming from the CTA
  • Section 679 rules on pre-immigration trusts
  • Best practices for counsel in overcoming challenges of foreign trusts

Faculty

Bakal, Scott
Scott J. Bakal

Shareholder
Greenberg Traurig

Mr. Bakal develops tax-planning strategies for closely held family businesses, partnerships, and publicly held...  |  Read More

Lipoff, Lawrence
Lawrence M. Lipoff, CPA, TEP, CEBS

Director
CohnReznick

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private...  |  Read More

Castro-Rodriguez, Daniel
Daniel Castro-Rodriguez

Associate
Greenberg Traurig

Mr. Castro-Rodriguez is an associate in the Tax Practice of Greenberg Traurig's Miami office. He focuses his...  |  Read More

Attend on March 28

Early Discount (through 03/01/24)

See NASBA details.

Cannot Attend March 28?

Early Discount (through 03/01/24)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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