Trust Distributions to Foreign Beneficiaries: Complex Planning and Calculation Challenges
Navigating the Interplay of Foreign Withholdings, Treaty Benefits, DNI Calculations, and Trust Compliance
Recording of a 110-minute CPE webinar with Q&A
This course will provide estate and trust tax advisers and compliance professionals with a thorough and practical guide to the tax compliance issues that fiduciaries face before making or allocating U.S. domestic trust or estate distributions to foreign beneficiaries. The panel will explain how to determine the U.S. status of foreign beneficiaries for U.S. tax purposes, detail how to calculate required withholding tax and net distribution amounts, discuss DNI implications of foreign beneficiaries, and explore the application of common tax treaty benefits.
- Classification and verification of residency status of beneficiaries
- Fiduciary accounting and DNI issues unique to domestic trusts with foreign beneficiaries
- Withholding requirements for domestic trust distributions to foreign beneficiaries
- Impact of tax treaty provision on domestic trusts with foreign beneficiaries
- Tax reporting requirements for domestic trusts and foreign beneficiaries
- Critical components of distribution planning and practice tips
The panel will discuss these and other critical questions:
- What must fiduciaries and their tax advisers know to verify the tax status of foreign or non-U.S. beneficiaries?
- What are the withholding requirements on distributions--either actual or allocated--to foreign beneficiaries?
- What are the reporting requirements for both the trust and its foreign beneficiaries on trust distributions?
- What impact do tax treaties have on calculation of net distributable amounts?
- What income items must be treated differently for fiduciary accounting income and DNI calculation purposes when a trust has a non-U.S. person as a beneficiary?
David V. Khanjyan
Loeb & Loeb
Mr. Khanjyan advises clients on the domestic and international aspects of income, estate and gift tax planning. He... | Read More
Mr. Khanjyan advises clients on the domestic and international aspects of income, estate and gift tax planning. He works with U.S. and non-U.S. individuals, families, trustees and businesses with multijurisdictional issues to structure tax-efficient plans.Close
Loeb & Loeb
Mr. Shen focuses his practice on domestic and international trusts and estate planning, with a particular emphasis on... | Read More
Mr. Shen focuses his practice on domestic and international trusts and estate planning, with a particular emphasis on gift, estate and generation-skipping tax planning for high-net-worth individuals and families. His practice includes the preparation of wills and trusts, estate and trust administration, and the representation of fiduciaries and beneficiaries in this regard. Mr. Shen also has experience counseling clients on charitable planning, including making charitable gifts and establishing public charities and private foundations.Close
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