(l-r) Jonathan Gopman, Victor Gabuardi, and Ryan Chusid of Nelson Mullins Riley & Scarborough. Courtesy photos New Proposed Guidance From the IRS on Foreign Trust Transactions and Large Gifts From Non-US Persons
This article summarizes the treatment of ownership of foreign trust assets; discusses the guidance for reporting a transfer and a donee's receipt of a distribution from a foreign trust, as well as the receipt of a large gift from an NRA; and addresses the treatment of certain loans with a foreign trust under the proposed regulations.
July 22, 2024 at 09:32 AM
7 minute read
On May 8, the IRS issued proposed regulations addressing matters related to foreign trusts and large gifts received from "nonresident aliens" (NRAs) by a U.S. person. See REG-124850-08 (proposed regulations). This article summarizes the treatment of ownership of foreign trust assets; discusses the guidance for reporting a transfer and a donee's receipt of a distribution from a foreign trust, as well as the receipt of a large gift from an NRA; and addresses the treatment of certain loans with a foreign trust under the proposed regulations.
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