events

Cross Border Trust Tax Panning and Compliance

When:
Hosted By:
New York Society of CPAs – International Taxation Conference
People:
Christopher R. Callahan
Location:
New York
Share on:

Agenda:

  • How to determine if a trust is foreign or domestic for US tax purposes.
  • How the US tax filings are different for foreign and domestic trusts.
  • Is a foundation a trust or a corporation for US tax purposes?
  • Can a Delaware trust be treated as a foreign grantor trust?
  • How to report income of a foreign non-grantor trust with US beneficiaries.
  • How IRC 684 may create a deemed sale for US tax purposes.
  • Attribution through a trust - how being a beneficiary of a trust could result in CFC reporting issues on Form 5471.
  • Should the US beneficiary file a Form 8621 - Indirect ownership of PFICs through a trust?
  • Pre-immigration tax planning using trusts.

Panelist:
Christopher R. Callahan, Partner, Fox Rothschild

CLE credits are available.