Form 4970 and Form 1041 Schedule J Accumulation Tax: Reporting Distributions From Foreign Trusts
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers with guidance on calculating trust accumulation distributions for beneficiaries of foreign trusts. The panel will detail the computations required to complete Schedule J of Form 1041. The panel will discuss the interdependence between Schedule J and the reporting of accumulation distributions on Form 4970 of beneficiaries’ individual tax returns.
Outline
- Default U.S. tax treatment of foreign non-grantor trusts with U.S. beneficiaries
- Throwback tax rules on distributions from UNI to U.S. beneficiaries
- Filing requirements and tax calculations
- Calculated/reported on Form 1041 Schedule J
- Accumulation distributions
- Throwback years and ordinary income accumulation (Part II)
- Taxes on undistributed net income (Part III)
- Long-term capital gains alternative tax election
- Allocation to beneficiaries (Part IV)
- Calculated/reported on Form 4970
- Income average and computation years (Part I)
- Calculating tax on accumulation distribution (Part II)
- Cross-referencing to Form 4970 and Form 1041
- Other foreign reporting requirements
Benefits
The panel will discuss these and other important topics:
- Identifying income that must be treated as UNI
- Calculating tax on distributions made out of UNI to a U.S. beneficiary on Form 4970 Part II
- Methodology for computing “throwback” taxes and reporting on Schedule J Part III
- Impact of electing alternative tax on long-term capital gains held by foreign trust
Faculty

Jack R. Brister, TEP
Managing Member
International Wealth Tax Advisors
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset... | Read More
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures which include foreign trusts, estates and foundations that have a U.S. connection, as well as foreign companies wanting to do business in the U.S. He also specializes in foreign investment in U.S. real property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures, FATCA registration, executives working and living abroad and annual reporting. He has been widely published, in addition to speaking at numerous international engagements.
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Alicea Castellanos
Managing / Co-founding Partner
Global Taxes
Ms. Castellanos specializes in U.S. tax planning and compliance for foreign individuals with U.S. source income,... | Read More
Ms. Castellanos specializes in U.S. tax planning and compliance for foreign individuals with U.S. source income, foreign individuals residing in the U.S., foreign persons investing in U.S. real property, U.S. persons residing abroad and foreign trusts with a United States connection.
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David Silver, CPA, TEP
Senior Manager
MBAF
Mr. Silver has experience with transactional planning including due diligence, operational and structural analysis. He... | Read More
Mr. Silver has experience with transactional planning including due diligence, operational and structural analysis. He provides tax, accounting, and consulting services to international and domestic corporations, partnerships, and high net worth individuals. He’s been involved in Trust and Estate planning for U.S. beneficiaries of foreign trusts and foreign beneficiaries of U.S. trusts. He also assists clients with pre-immigration, expatriation, and tax structuring to achieve maximum worldwide income and estate tax efficiency. He works with high net worth individuals and organizations in various industries.
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