Comments of the American College of Trust and Estate Counsel (ACTEC) on Proposed Regulations Regarding Transactions With Foreign Trusts and Information Reporting on Transactions With Foreign Trusts and Large Gifts
Private Wealth Services attorney Kevin Packman collaborated with The American College of Trust & Estate Counsel (ACTEC) to prepare comments submitted to the Internal Revenue Service (IRS) on proposed regulations concerning foreign trust transactions. These remarks provide insight into the proposed regulations, which affect individuals in the U.S. engaging in international transactions, those treated as the owner of foreign trusts and recipients of significant gifts from foreign individuals. ACTEC's recommendations encompass broadening the definition of qualified obligation, introducing greater flexibility in penalty abatements for failure to report certain foreign large gifts and advocating for the inclusion of a new question in form 3520 addressing the reporting of a domestication of a foreign trust, which would bring clarity to Prop. Reg. § 1.6048-4(b)(4).