The Knight Watch: Proposed Regulations Add Clarity and Confusion to an Area Replete with Penalties

Tax attorney Kevin Packman published a Knight Watch column in TAXES – The Tax Magazine reviewing the IRS' proposed regulations regarding foreign trusts and foreign gifts. The 150-plus pages of proposed rules, released on May 8, 2024, affect Sections 643(i), 679, 6039F, 6048 and 6677 of the Internal Revenue Code, which pertain to activities including receiving loans from foreign trusts, reporting gifts from foreign persons and transferring assets to a foreign trust. Mr. Packman's article breaks down each of the activities touched by the proposed regulations, providing comprehensive analysis of what taxpayers and their advisers should know.

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