Proposed regulations (REG-124850-08) issued Tuesday by the IRS provide guidance on information reporting of transactions with foreign trusts and the receipt of large foreign gifts. The rules are, in ...
United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she ...
An IRS rule proposal could give tax professionals and clients who receive assets through foreign trusts and gifts answers to technical questions they've been posing for decades. The IRS proposal would ...
In this global economy, it’s becoming increasingly common for U.S. citizens and residents to have financial ties overseas. These financial ties often come in the form of foreign bank accounts, real ...
Cross-border asset protection planning involves delicate balancing of ensuring that trusts are properly classified because foreign trusts carry significant and expensive reporting obligations that are ...
New Proposed Guidance From the IRS on Foreign Trust Transactions and Large Gifts From Non-US Persons
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 ...
On May 7, 2024, the U.S. Treasury and Internal Revenue Service issued proposed regulations that provide guidance regarding information reporting of ownership, transfers to and receipt of distributions ...
As the Internal Revenue Service continues to crack down on U.S. taxpayers who fail to report foreign-sourced income, a recent case illustrates the inherent reporting difficulties faced by individuals ...
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