5/2019 Publications

Analyzing Foreign Trusts

This panel focuses on the application of the US tax laws as they relate to identifying foreign versus domestic trust structures. This panel outlines a roadmap from which to analyze trust deeds and discussed some of the key nuances in the grantor trust rules that cause the practitioner to reexamine the trust based on direct/indirect transfers to the trust or changes in the income tax residency of the trust parties. American Bar Association Section of Taxation – 2019 May Meeting. May 11, 2019.