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Treasury and the IRS recently issued proposed regulations regarding reporting of transactions with foreign trusts and the receipt of foreign gifts (“Proposed Regulations”). The Proposed Regulations affect US persons who are grantors or beneficiaries of foreign trusts and US persons who receive gifts or bequests from foreign persons. These rules are the most significant development regarding reporting for US persons with interests in foreign trusts since 1997, and they raise many questions for foreign trusts with US-connected persons. Many of those uncertainties are highlighted in recommendations and comments to Treasury by more than 1,000 practitioners and interested stakeholders, including the American College of Trust and Estate Counsel (ACTEC), the Tax Section of the American Bar Association (ABA) and the New York State Bar Association.
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