Complimentary for Members

On-Demand Self-Study

Cross Border Trust Taxation - International Taxation Conference - 06/01/2024

On-Demand Self-Study
- How to determine if a trust is foreign or domestic for US tax purposes. - How the US tax filings are different for foreign and domestic trusts. - Is a foundation a trust or a corporation for US tax purposes? - Can a Delaware trust be treated as a foreign grantor trust? - How to report income of a foreign non-grantor trust with US beneficiaries. - How IRC 684 may create a deemed sale for US tax purposes. - Attribution through a trust - how being a beneficiary of a trust could result in CFC reporting issues on Form 5471. - Should the US beneficiary file a Form 8621 - Indirect ownership of PFICs through a trust? - Pre-immigration tax planning using trusts.

Major Topics

  • How to determine if a trust is foreign or domestic for US tax purposes.
  • How the US tax filings are different for foreign and domestic trusts.
  • Is a foundation a trust or a corporation for US tax purposes?
  • Can a Delaware trust be treated as a foreign grantor trust?
  • How to report income of a foreign non-grantor trust with US beneficiaries.
  • How IRC 684 may create a deemed sale for US tax purposes.
  • Attribution through a trust
  • how being a beneficiary of a trust could result in CFC reporting issues on Form 5471.
  • Should the US beneficiary file a Form 8621
  • Indirect ownership of PFICs through a trust?
  • Pre-immigration tax planning using trusts.

CPE Credits Available

0
Taxation (NYSED) - NYSED

Things to Know About This Course

Course Level

  • Update

Professional Area of Focus

  • Taxation (NYSED)

Prerequisites

None

Advanced Preparation

None

Intended Audience

Firms and individuals who have clients, with international investments or business, and individuals who are considering moving in or out of the United States. CFO’s, CEO’s, tax director, etc. who are managing global worldwide businesses. Hedge Funds, Real Estate, IT Industries, Shipping Companies, Service Industries and Manufacturing Companies

Provider

Foundation for Accounting Education

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