“In the common nomenclature, the term “foreign trust” means a trust that is governed by the laws of a foreign country. For tax purposes, the term “foreign trust” is a term of art. Pursuant to Code Section 7701(a)(31)(B), a foreign trust is any trust other than a domestic trust. A domestic trust, pursuant to Code Section 7701(a)(30)(E), is a trust that meets both the “court test” and the “control test.”
Court Test
To meet the court test, a court in the U. S. must be able to exercise primary supervision over the administration of the trust.
The term “primary supervision” means that a court has or would have the authority to determine substantially all issues regarding the administration of the entire trust. Administration includes maintaining books and records, filing tax returns, managing and investing the assets of the trust, defending the trust from suits by creditors, and determining the amount and timing of distributions. If both a U. S. court and a foreign court can exercise primary supervision then the trust will also satisfy the court test.”
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Jacob Stein, Esq. is Managing Partner at Aliant, LLP. He specializes in structuring international business transactions, complex U.S. and international tax planning and asset protection planning.
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Jacob Stein, Esq.
Aliant, LLP
Jacob Stein, Esq. is Managing Partner at Aliant, LLP. He specializes in structuring international business transactions, complex U.S. and international tax planning and asset protection planning.
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