Reporting Obligations of U.S. Beneficiaries of Foreign Trusts and New Form 8938

In 2010, Congress enacted the Foreign Account Tax Compliance Act (FATCA) as part of the Hiring Incentives to Restore Employment Act ("the HIRE Act"), and the legislation amended the Internal Revenue Code with the goal of increasing foreign account tax reporting and compliance. [The Hiring Incentives...

Final Regs on Income Ordering Rules for Payments to Charitable Beneficiaries

For a trust to qualify for the charitable deduction, a charitable contribution must be made from gross income. [ See IRC § 642(c) .] IRC Section 642 requires tracing since the source of the charitable contribution must be gross income rather than principal. The provisions of the governing instrument...

Reporting Obligations of U.S. Beneficiaries of Foreign Trusts and New Form 8938

In 2010, Congress enacted the Foreign Account Tax Compliance Act (FATCA) as part of the Hiring Incentives to Restore Employment Act ("the HIRE Act"), and the legislation amended the Internal Revenue Code with the goal of increasing foreign account tax reporting and compliance. [The Hiring Incentives...