January 27, 2016

International Estate and Gift Planning for Non-Citizens

What is FIRPTA? The Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) allows the IRS to tax foreign persons on the disposition of real […]
March 26, 2014

Foreign non-grantor trust with US beneficiary

Basically, any trust not considered a grantor trust is by default a non-grantor trust and treated as its own taxpayer. For example, the result of a […]
March 26, 2014

Tax and reporting considerations of a foreign grantor trust

A grantor, for U.S. tax purposes, is any person that either creates a trust or directly or indirectly funds a trust. In order for a foreign […]
March 26, 2014

Methods to determine whether a trust is foreign or domestic

Generally, the IRS will not issue an advance ruling on whether or not a trust is foreign or domestic. Therefore, it is left up to the […]
March 26, 2014

Foreign trust distributions for tax purposes

A trust is essentially a device under which a settlor (person creating the trust) provides assets to trustees to hold and manage for the benefit of […]
March 26, 2014

Receiving gift or bequest from foreign individual

Traditionally, under United States taxing principles a transferor (party making a gift) making a gift or bequest is the one subject to transfer tax (gift or […]