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In previous articles, I discussed the §318 downstream and upstream attribution rules; in that context, I also mentioned that there were special rules concerning grantor trusts and tax-exempt employee trusts. This article will cover the special §318 grantor trust attribution rules. §318 Grantor Trust Attribution: Definition of Grantor Trust A grantor trust is any trust […]
In a previous article, I discussed the Internal Revenue Code (“IRC”) §318 downstream trust attribution rules. Today, I would like to focus on the §318 upstream trust attribution rules. §318 Upstream Trust Attribution: Downstream vs. Upstream There are two types of §318 trust attribution: downstream and upstream. In a previous article, I already covered the […]
In this article, I would like to introduce the readers to the concept of US information returns; I will also explore the differences between US information returns and US tax returns. US Information Returns: Two Types of Returns The US tax system is a self-assessment system where taxpayers must file certain forms or returns developed […]
As I was preparing for this presentation today, it occurred to me that there is a sixth trap which is not really common but it does exist. It’s not really even limited to Business Lawyers; it really exists throughout the profession but because it’s such an important trap, I decided to share it with you. […]
Many taxpayers and even tax professionals are completely unaware of the fact that FBAR needs to be filed not just by individuals, businesses and trusts, but also by estates. In this article, I will discuss FinCEN Form 114 Estate filers (i.e. estates that need to file FinCEN Form 114). FinCEN Form 114 Estate filers: FBAR […]