United States: Decoding Cross-Border Tax Compliance: CFCs, PFICs, Foreign Trusts & Foreign Gifts And Bequest

The purpose of this paper is to "decode" the complex reporting obligations imposed on U.S. persons with respect to their interests in certain offshore entities. More specifically, this paper will focus on two aspects of international tax compliance which can be perceived as "traps for the unwary." First, the paper will focus on the obligation imposed on U.S. persons to report certain transactions with foreign corporations, including the requirement to file a Form 5471 to report certain acquisitions, dispositions or maintenance of interests in a foreign corporation. The paper will then focus on the obligation to report certain transactions with foreign trusts and persons, including the obligation to file a Form 3520 to report distributions from foreign trusts and the receipt of large foreign gifts or inheritances. Read >>