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

The Foreign Account Tax Compliance Act amended the IRC to improve tax reporting and compliance with respect to foreign accounts and foreign assets. Among these changes were new reporting requirements that affect United States beneficiaries of foreign trusts. In this Analysis, Diane L. Mutolo discusses...

Personal Liability of a Fiduciary under the Federal Priority Statute for Unpaid Federal Taxes of an Estate and Recent U.S. District Court Decisions

By Diane L. Mutolo J.D. LL.M. An estate fiduciary may be held personally liable for the estate's unpaid taxes. IRC § 6901 provides that the government may collect a fiduciary's liability under the Federal Priority Statute ( 31 U.S.C. § 3713 ) for an unpaid claim of the Government...