Webinar: US Taxation of Foreign Trusts Bootcamp - Fundamentals of U.S. Taxation for Foreign Trusts

A fast-paced bootcamp on U.S. tax rules for foreign trusts led by Milan Solarz-Patel (former IRS trial attorney) and ACTEC Fellow Amy Jetel. In one hour, they cover how trusts are classified (court test, control test), foreign vs. domestic status, grantor vs. non-grantor outcomes, and what that means for U.S. owners and beneficiaries. You’ll see how DNI/UNI, accumulation distributions, and the throwback tax work; practical mitigation (annual DNI payouts, distribution sequencing, restructuring, investment choices, PPLI); key reporting (Forms 3520/3520-A and related pitfalls); penalties and reasonable-cause relief; hybrid/reverse-hybrid designs; estate-tax exposure for non-U.S. persons and transfer certificates; pre-immigration trust planning; and when protective filings help start the statute clock. Educational content only.

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