Download or read book United States Taxation of Foreign Trusts written by Charles Bruce and published by Springer. This book was released on 2000-03-30 with total page 410 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explanation and comments upon the U.S. tax and reporting rules applicable to foreign trusts. Examples of suggested courses of action for common problems are given throughout.
Download or read book Federal Taxation of Trusts Grantors and Beneficiaries written by John L. Peschel and published by Warren Gorham & Lamont. This book was released on 1989 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Foreign Trusts and Foreign Estates written by and published by . This book was released on 1977 with total page 472 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2019-05-02 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
Download or read book U S Taxation of Foreign Estates Trusts and Beneficiaries written by Howard M. Zaritsky and published by . This book was released on 2007-01-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... explains in detail the federal income, estate, and gift taxation of foreign trusts and estates and their grantors and beneficiaries. An entity is subject to U.S. income taxation as a foreign trust or estate if it is classified as a foreign trust or estate, respectively, for U.S. tax purposes.
Download or read book The U S May Be a Good Trust Jurisdiction for Foreign Persons written by G. Warren Whitaker and published by . This book was released on 2006 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: At one time non-U.S. persons would rarely consider creating a trust that was subject to the jurisdiction and governed by the substantive law of one of the fifty United States. The definition of what constituted a U.S. trust for income tax purposes was vague and amorphous, and US trusts are subject to U.S. income tax on their worldwide income, while non-U.S. trusts are taxed only on their U.S. source income. However, recent changes in U.S. tax law have made it possible to create a trust with a U.S. trustee that is subject to U.S. court supervision and governed by the laws of a U.S. state, and still achieve all the tax advantages of a foreign trust. In addition, certain states have enacted substantive trust laws that are attractive for anyone who wants to create a trust, including non-U.S. persons. Among the recent changes in the tax law that permit foreigners to use U.S. trusts are: 1. The revised definition of "United States Trust" enacted by Congress in 1996 creates a two-pronged bright line test, and only trusts that meet both tests are considered to be U.S. trusts. The tests make it possible to create a trust under US law that nonetheless qualifies as a foreign trust. 2. Several U.S. states now permit a Settlor to contribute assets to an irrevocable trust and remain a permissible beneficiary of the trust in the discretion of an independent trustee, and the trust assets will be protected from creditors whose claims arise after the trust is created, and thus also potentially excluded from U.S. estate tax at the Settlor's death. 3. The rules regarding grantor trusts with non-U.S. grantors were also significantly amended in 1996. 4. Certain countries have lists of jurisdictions that are considered to be tax havens. The U.S. is not on any of these lists. 5. Income tax treaties between the United States and certain other countries provide benefits to non-U.S. persons residing in these treaty countries who create and fund U.S. domestic trusts. 6. The income taxes of the United States on passive income have been dramatically reduced in recent years in order to avoid taxation in their home country. The substantive advantages that make U.S. trusts attractive to foreigners include: 1. No Rule Against Perpetuities in some states. 2. Investment Advisor with sole responsibility for investment management. 3. Distribution Advisor 4. Protection From Forced Heirship 5. Private Trust Companies.
Download or read book International Trust Laws written by Paolo Panico and published by Oxford University Press, USA. This book was released on 2010-02-18 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Trust Laws provides broad ranging and practical coverage of the most important issues in international trust law. It analyzes topics including protectors, shams, beneficiaries' right to information and protection from heirs and creditors, examining their development under English law and across a wide range of jurisdictions.
Download or read book United States Taxation of Foreign Estates Trusts and Beneficiaries written by Michael A. Heimos and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "... gives a survey of the history of trusts, explains in detail the U.S. federal income, estate, and gift taxation of foreign trusts and estates and their grantors and beneficiaries. The Portfolio also provides a secondary discussion of select U.S. state taxation analogues. An entity is subject to U.S. income taxation as a 'foreign trust' or "foreign estate" if it is classified respectively as such under several U.S. tax code sections"--Page iii.
Download or read book The Worlds of the Trust written by Lionel Smith and published by Cambridge University Press. This book was released on 2013-08-22 with total page 585 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the common belief that they are found only in the common law tradition, trusts have long been known in mixed jurisdictions even where they have a civilian law of property. Trusts have now been introduced by legislation in a number of civilian jurisdictions, such as France and China. Other recent developments include the reception of foreign trusts through private international law in Italy and Switzerland and the inclusion of a chapter on trusts in Europe's Draft Common Frame of Reference. As a result, there is a growing interest in the ways in which the trust can be accommodated in civil law systems. This collection explores this question, as well as general issues such as the juridical nature of the trust, the role and qualifications of the trustee and particular developments in specific jurisdictions.
Download or read book Foreign Trusts Estates and Beneficiaries written by Howard M. Zaritsky and published by . This book was released on 1981 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book An Overview Concerning Certain Recent Changes for Foreign Compensatory Trusts written by Steven W. Rabitz and published by . This book was released on 2000 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article describes some of the issues confronting the foreign deferred compensatory trust world in light of recent changes to Sections 671, 672 and 679 of the Internal Revenue Code and regulatory authority thereunder. In addition to addressing the recent changes in law that refine the boundary between domestic and foreign trusts, the article highlights some of the issues surrounding "inbound" and "outbound" compensatory arrangements which involve trusts. In particular, the article addresses proposed regulations which may subject U.S. entities and certain foreign entities to U.S. Federal income tax on the items of income produced by foreign compensatory trusts, regardless of whether the trusts would otherwise be treated as "grantor" trusts under the Internal Revenue Code. While these proposed rules are intended to address policy concerns regarding U.S. persons who do not pay their fair share on income attributable to foreign trusts, they also may impact the boundary between Section 402(b) "secular" trusts and the grantor trust rules with various potential practical and policy consequences and questions for foreign compensatory arrangements.
Download or read book The World Trust Survey written by Charles Gothard and published by Oxford University Press, USA. This book was released on 2010 with total page 609 pages. Available in PDF, EPUB and Kindle. Book excerpt: The use of international trusts continues to expand, and practitioners increasingly need to be aware of cross-border considerations. This title provides a concise and practical overview of the key aspects of law and practice in all the key jurisdictions offering trusts. Private and commercial trusts are established under the law of an increasing number of jurisdictions, which are competing to attract trust business, and these laws are often dissimilar. As international trusts mature, established trust jurisdictions are changing their laws to comply with the legal demands and standards imposed by international agencies, as well as to meet the legitimate expectations of the institutional investor. The courts of international centers are also developing their own jurisprudence. In addition, jurisdictions new to trusts are introducing trusts in the vehicles which they offer investors, and legislation from these new trust centers is opening up new routes for international investment and tax mitigation. This book provides a comprehensive treatment of the subject, covering all the key on-shore and off-shore jurisdictions that practitioners typically encounter. It offers a very practical overview of the subject using a questionnaire format for each country, avoiding academic material, and giving concise answers to the sorts of frequently asked questions that arise in trust law and practice. The questionnaire covers a full range of subjects such as the mechanics of trusts, issues such as anti-money laundering laws and conflicts of laws, shams, protectors, and forced heirship as well as the different types of trusts used in a jurisdiction. Formerly an annual special issue in the journal Trusts & Trustees, this title has been improved and extended with a reworked questionnaire, new countries and contributors, and a new editor, Charles Gothard.
Download or read book Taxation of Trusts written by Vicki Ammundsen and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "An essential guide for any trust practitioner or trustee, this book provides a comprehensive overview of how the tax laws apply to settlors, trustees and beneficiaries. The third edition of Taxation of Trusts has been updated to incorporate recent developments in charity and trust case law, the application of FATCA to trusts, reforms to the disclosure requirements for foreign trusts, new tax changes affecting land-owning trusts, and other legislative reform that affect the tax obligations of trusts. The text also includes practical examples and summaries of recent tax and charity cases. Presented in a user-friendly format, the book seeks to answer questions that are arise in practice. Each chapter includes relevant legislation for the subject matter covered. Topics covered include: trustee income and distributions trustees' liability for tax beneficiary income and distributions tax avoidance classification of trusts for tax purposes trust migration trading trusts foreign trusts qualifying and look-through companie's life leases and debt forgiveness imputation and RWT credits associated person's variation and resettlement charitable trusts."--Wolters Kluwer CCH Website.
Download or read book Foreign Asset Protection Trusts Tax and Other Considerations written by Pullis Robert and published by LAP Lambert Academic Publishing. This book was released on 2015-07-23 with total page 148 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is written mainly for the U.S. attorney and/or affluent individual. It discusses certain aspects of using foreign trusts for the purpose of protecting one's own assets from potential future creditors. The author, having been a practicing estate-planning attorney since 1999, is a strong proponent of using foreign asset-protection trusts (FAPT's) to protect client assets. After all, what good does it do to create an elaborate estate plan if the client is left to lose everything in a future lawsuit? Preserving the client's estate should be the first consideration in the estate-planning process. This book explains how there are many countries around the world that have specific laws established that allow you (or your client) to establish an asset-protection trust in order to protect one's own assets from one's future creditors. Such countries will NOT honor any court judgment rendered outside of its own jurisdiction that would cause a seizure of trust assets by a judgment creditor.
Download or read book Trusts written by Maurizio Lupoi and published by Cambridge University Press. This book was released on 2000 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comparative study covering three models of trust : the English, the international and the civilian. More than forty countries are examined and a unified theory of trusts is submitted. The effects of the Hague Convention of 1985 are discussed, as well as its implementation in ratifying civil law countries, where it is now possible to form trusts under a foreign law.
Download or read book U S Taxation of Foreign Estates Trusts and Beneficiaries written by Howard M. Zaritsky and published by . This book was released on 2001 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
