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New Member
posted Jun 4, 2019 1:55:02 PM

Foreign trust definition

What can be considered a foreign trust?

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1 Replies
Level 15
Jun 4, 2019 1:55:04 PM

" What can be considered a foreign trust?"

A foreign trust is any trust other than a domestic trust, per Treas. Reg. §301.7701-7(a):

(1) A trust is a United States person  if -

(i) A court within the United States  is able to exercise primary supervision over the administration of the trust (court test); and

(ii) One or more United States persons  have the authority to control all substantial decisions of the trust (control test).