Date: 2024-05-08
Links to Federal Register: HTML, PDF
Document Number: 2024-09434, RIN: 1545-BI04
Action: Notice of proposed rulemaking and notice of public hearing.
Abstract: This document contains proposed regulations that provide guidance regarding information reporting of transactions with foreign trusts and receipt of large foreign gifts and regarding loans from, and uses of property of, foreign trusts. This document also contains proposed amendments to the regulations relating to foreign trusts having one or more United States beneficiaries. The proposed regulations affect United States persons who engage in transactions with, or are treated as the owners of, foreign trusts, and United States persons who receive large gifts or bequests from foreign persons. This document also provides notice of a public hearing on the proposed regulations.
Notable phrases | Frequency |
---|---|
form 3520 | 214 |
section 643(i) distribution | 125 |
u.s. grantor or beneficiary | 113 |
use of trust property | 80 |
cash or marketable securities | 61 |
foreign gifts | 57 |
nonresident alien | 55 |
loan of cash or marketable securities | 51 |
foreign nongrantor trust | 47 |
gross reportable amount | 40 |
foreign grantor trust | 36 |
dual resident taxpayer | 35 |
distribution from a foreign trust | 30 |
reasonable cause | 26 |
foreign nongrantor trust beneficiary statement | 16 |
foreign grantor trust beneficiary statement | 16 |
married u.s. persons | 16 |
treated as having a u.s. beneficiary | 16 |
fair market value exception | 13 |
foreign grantor trust owner statement | 11 |
loan or use of trust property | 11 |
qualified stated interest | 11 |
knows or has reason to know | 10 |
treated as an exchange | 9 |
paid or accumulated for the benefit | 8 |
use of property of a foreign trust | 7 |
Reg. Cites | Frequency |
---|---|
1.6048-4 | 45 |
1.6048-2 | 30 |
1.6048-4(a) | 20 |
1.643(i)-2(b)(2)(iii) | 17 |
1.679-1 | 15 |
1.643(i)-1(d)(9) | 14 |
1.1001-3 | 14 |
1.679-1(c)(5) | 12 |
1.6048-5 | 12 |
1.6048-3 | 11 |
1.6039F-1(a) | 11 |
301.7701(b)-7(a)(1) | 10 |
1.643(i)-3(c) | 10 |
1.643(i)-2 | 10 |
1.6048-4(b) | 10 |
1.643(i)-1 | 10 |
1.6048-3(a) | 9 |
1.6012-1(b)(2)(ii) | 8 |
1.679-1(a) | 8 |
Sec. Cites | Frequency |
---|---|
643(i) | 174 |
6048 | 35 |
679 | 35 |
6048(c) | 18 |
6677 | 18 |
6048(a) | 15 |
6081 | 14 |
6039F | 13 |
501(c)(3) | 13 |
6048(b) | 9 |
501(a) | 9 |
6013 | 8 |
7701(a)(30) | 8 |
2801(e) | 8 |
2801 | 6 |
6048(d)(2) | 5 |
501(c) | 5 |
679(c)(6) | 5 |
2512 | 5 |
Statistics
Number of pages: 46, words: 55,463, sentences: 2,050
Average words per sentence: 27