Third-party promoters routinely market trust arrangements as a means for taxpayers to avoid or defer federal income taxes. So much so, in fact, that the IRS has a designated webpage to warn taxpayers ...
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for ...
In Private Letter Ruling 202528006 (July 11, 2025), the Internal Revenue Service confirmed that merging two generation-skipping transfer (GST) tax-exempt irrevocable trusts created by different ...
On the last workday of the year, December 29, 2023, the IRS issued a Chief Counsel Memorandum adding a wrinkle to one of the most estate planning techniques – to give assets away for estate tax ...
Foreign trusts routinely cause U.S. reporting headaches for taxpayers. Generally, tax professionals must grapple with both the language used in the trust and applicable foreign law to determine the ...
The original SECURE Act changed the game for payouts for most IRA beneficiaries, including trusts. Congress eliminated the stretch IRA deferral advantage and replaced it with a 10-year rule, requiring ...
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