Hal J. Webb presents at the "How the U.S. Treats Foreign Corporations and Trusts" event hosted by Transcontinental Trusts: International Forum 2016.
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This article briefly summarizes the attribution rules applicable to partnerships and corporations under Section 318 and provides some practical tips for dealing with the rules.
Trusts are a classic planning tool for the transfer of a family's wealth down to future generations. However, a number of tax, planning, and practical issues should be considered when evaluating the domestication of foreign trust structures.