In this course we will review ways in which a domestic trust can inadvertently become foreign. We will discuss the court and control tests and the rules for grantor trusts. We will review common problems that can cause domestic trusts to be taxed as foreign. We will also identify some tools available under the Tax Code and Regulations to resolve common problems.
Objectives:
1) Learn the court and control tests
2) Identify two common scenarios that can create an inadvertent foreign trust
3) Understand the problem of capital gain recognition and some exceptions to this rule
RUTH MATTSON is a partner of Vacovec, Mayotte & Singer LLP in Newton. She concentrates in international and multinational estate planning, multinational estate administration, sophisticated estate and business planning, local estate and trust...
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