@msosso51 whereas we lack some information as to the country where this Trust is registered and therefore the laws of such a country regarding trust ( Grantor trusts specifically ) and therefore treaty assertions ) the following excerpt from statute ( section 988 ) suggests that you are not subject to 988 regs because this is not a 988 transaction ----->
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(1)Section 988 transaction
(A)In general The term “section 988 transaction” means any transaction described in subparagraph (B) if the amount which the taxpayer is entitled to receive (or is required to pay) by reason of such transaction—
(ii) is determined by reference to the value of 1 or more nonfunctional currencies.
(B)Description of transactions
For purposes of subparagraph (A), the following transactions are described in this subparagraph:
(ii) Accruing (or otherwise taking into account) for purposes of this subtitle any item of expense or gross income or receipts which is to be paid or received after the date on which so accrued or taken into account.
(iii) Entering into or acquiring any forward contract, futures contract, option, or similar financial instrument.
The Secretary may prescribe regulations excluding from the application of clause (ii) any class of items the taking into account of which is not necessary to carry out the purposes of this section by reason of the small amounts or short periods involved, or otherwise. "
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