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 ...

Foreign trust reporting obligations can apply to a domestic trust established even within the US and the recent regulations make compliance more ... Tax Implications of Foreign Trust Classification.

"Since 1996, when Congress enacted a myriad of provisions to prevent tax avoidance through the use of foreign trusts and gifts, taxpayers have had to rely on less formal guidance (e.g., Notice 97 ...

Form 3520-A is the Annual Information Return of Foreign Trust With a U.S. Owner. A foreign trust with at least one U.S. owner files this form annually to provide information about: the trust, its ...

The IRS had been automatically assessing penalties for late-filed Forms 3520, Part IV, which deal with reporting foreign gifts and bequests, at the time when they were filed. National Taxpayer ...

Matthew F. Erskine is a trusts and estates attorney. Follow Author. Mar 17, 2025, 01:45pm EDT. Share. Save. Book with title Report of Foreign Bank and Financial Accounts ... When the IRS ...

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. Last month, the agency ...

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 ...