Confidently handle your client's trust needs - get a thorough understanding of foreign trust administration.
Many U.S. taxpayers have or are considering establishing a foreign trust for privacy, asset protection or other purposes. In addition, many nonresident aliens establish foreign trusts before moving to the U.S. This topic will help you understand the different types of foreign trusts, how they are administered, the U.S. tax treatment of foreign trusts and their grantors and beneficiaries. It will also help you understand and comply with the FATCA rules and the new withholding tax applicable to foreign entities, including foreign trusts.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Overview of Foreign Trust Issues
When Is a Trust a Foreign Trust
- Foreign Governing Law
- Change in Situs and Governing Law Provisions
- Liechtenstein Siftungs, Swiss Foundations; Panama Foundations; Nevis Privacy Trusts
- Foreign Trustees
Types of Foreign Trusts
- Foreign Grantor Trusts
- Foreign Nongrantor Trusts
- Simple vs. Complex Trusts
- Absolute vs. Discretionary Trusts
- Privacy Trusts
- Asset Protection Trust
Administration of Foreign Trusts
- Corporate Trustees
- Letters of Wishes
- Protectors
- U.S. Persons as Excluded Beneficiaries
- S. Tax Issues
- Classification of Foreign Entities as Trusts or Corporations
- Section 679
- U.S. Grantor
- Foreign Grantor and 5 Year Rule
- Form 3520 and 3520-A
- Accumulation Distributions
- Nonqualifying Loans From the Foreign Trust
- FATCA
- Professional Trustees and Participating FFI Status
- Other Trustees and NFFE Status
- Reporting by Foreign Trust
- Reporting by U.S. Beneficiary on Form 8938
FinCEN Form 114 Reporting Requirements
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on June 14, 2016.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Charles S. Kolstad
Withers Bergman LLP
- Tax partner Withers Bergman LLP, a leading international private capital law firm, specializing in international tax matters
- Focuses his practice on international tax, corporate, and partnership matters; he assists clients in tax and corporate planning relating to the acquisition, disposition and restructuring of businesses, corporations and partnerships both domestically and internationally
- Frequently advises foreign individuals moving to the U.S. on pre-immigration, income, gift and estate tax planning opportunities; he also focuses his practice on the cannabis industry/cannabusiness, crypto assets and block chain technology, and tax issues related to initial coin offerings (ICOs)
- Has advised over 200 clients with unreported foreign 1nancial accounts, foreign trusts, and other foreign investments, on the 1ling of FBARs and other information returns, and whether participating in the IRS’s various offshore voluntary disclosure programs is appropriate
- Written and lectured on the extensive information reporting requirements for U.S. taxpayers with international business operations
- During his career he’s been at Mitchell Silberberg & Knupp LLP and Venable LLP and was a tax partner at both Coopers & Lybrand and Ernst & Young
- J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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