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Analyzing Foreign Trusts

  • picture of Alexander M. Lewis
    Alexander M. Lewis

This panel focuses on the application of the US tax laws as they relate to identifying foreign versus domestic trust structures. This panel outlines a roadmap from which to analyze trust deeds and discussed some of the key nuances in the grantor trust rules that cause the practitioner to reexamine the trust based on direct/indirect transfers to the trust or changes in the income tax residency of the trust parties. American Bar Association Section of Taxation – 2019 May Meeting. May 11, 2019.