Federal taxation of foreign trusts: coping with a complex regime. (part 1)

Article Abstract:

The Small Business Job Protection Act of 1996 established guidelines regarding the classification and taxation of foreign trusts. The two key elements of defining whether foreign trusts exist for tax purposes are whether US court can exert jurisdiction over such a trust and whether US fiduciaries exert control over the trust. These two elements represent the simpler aspects of the complex field of foreign trusts.

Beneficiaries, international

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Choosing the best depreciation alternative for trust property

Article Abstract:

The author explains how depreciation of trust property can affect beneficiaries and describes various methods for handing depreciation issues. Topics include the effects of the grantor's options, income tax treatment of depreciation, passive loss rules, and the sharing of trust property between income and principal beneficiaries.

States, Analysis, Financial planning, Depreciation

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Prop. regs. on ESBTs: more guidance for family trusts owning S stock

Article Abstract:

The authors analyze proposed IRS regulations aimed at clarifying the elements of an electing small business trust, the requirements of an ESBT election, and the taxation of ESBTs.

S corporations, Family-owned businesses, Family corporations

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