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FATCA - Foreign Trusts Treated As Having U.S. Beneficiaries
FATCA - Foreign Trusts Treated As Having U.S. Beneficiaries
FATCA - Foreign Trusts Treated As Having U.S. Beneficiaries
Beneficiaries
If any person has the discretion (by authority given in the trust
agreement, by a power of appointment or otherwise, of making a
distribution from the trust to or for the benefit of any person), the trust will
be treated as having a beneficiary who is a U.S. Person, unless the trust
terms specifically identify the class of person to whom such distribution
may be made and none of those persons are U.S. Persons during the tax
year (IRC §679(c)(4) as added by the 2010 HIRE Act).
Gary S. Wolfe
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email: gsw@gswlaw.com