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Article on Foreign Trusts

By Gerry W. Beyer

Foreignglobe

Marianne R. Kayan & Ashley A. Weyenbergrecently published an article entitled, Foreign Trusts: Form 3520 and Form3520-A: Filing Deadlines and Liability of a Decedent’s Estate, 27 Prob. & Prop. 56(July/August 2013).  Provided below is the introduction to the article:

The IRS requires certain U.S. persons to fileinformational returns to report their relationships to, and transactions with,foreign trusts. Internal Revenue Code § 7701(a)(30). This requirement alsoimposes the responsibility to file such informational trust returns on theestates of some deceased U.S. persons. Informational returns are just that,used to report certain information, but not to directly impose taxes. Thisarticle specifically explores the effects of these filing requirements on theexecutors of the estates of U.S. decedents, while also considering the effectof the open-ended Offshore Voluntary Disclosure Program (OVDP), offered by theIRS as an option to seek resolution of prior filing mistakes or omissions.

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Articles, Income Tax and Trusts