Tag Archives: non-grantor trust

Expatriation – U.S. Income Tax Filing and Reporting

May 01, 2013  |   Posted by :   |   Expatriation   |   0 Comments

Under IRC Sec. 6039G, Tax Act 2008, the ensuing IRS Notice 2009-85 (IRS Notice 2009-85) expands the U.S. tax filing and reporting that is due from covered expatriates in years following the year of expatriation. Prior to the 2008 Tax Act, (“HEART Act”), a covered expatriate was required to file annual information returns on Form […]

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Expatriation: Non-Grantor Trusts

April 05, 2013  |   Posted by :   |   Expatriation   |   0 Comments

A covered expatriate’s interest in a non-grantor trust is not subject to the “mark-to-market tax”. Instead, the taxable portion of distributions to a covered expatriate, who was a beneficiary (but not an owner) of a trust on the day before the expatriation date are subject to a 30% withholding tax. Under HEART (tax legislation), a […]

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Expatriation and the Ten Year Rule

March 20, 2013  |   Posted by :   |   Expatriation   |   0 Comments

Expatriates who left the U.S. prior to June 17, 2008 are covered under prior tax rules, contained in three separate Tax Acts, which each subject U.S. expatriates to a ten-year “alternative tax regime” on U.S. source income; i.e. for ten years after expatriation, the expatriate is required to file a U.S. income tax return, to […]

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FBAR – U.S. Trustee Foreign Non-Grantor Trust

May 31, 2012  |   Posted by :   |   FATCA/FBAR   |   0 Comments

A U.S. trustee of a foreign non-grantor trust must file Form TD F 90-22.1 if the Trustee has a financial interest in or signature authority or other authority over any financial accounts, including bank, securities, or other types of financial accounts in a foreign country if the value of such accounts exceeds $10,000. A person […]

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