The IRS requires an annual written notice of reportable events such as the transfer of money or property to a foreign trust, the creation of a foreign trust, or the death of a U.S. citizen who was an owner of a foreign trust. In addition, the identity of each trustee, each trust and each beneficiary, also needs to be included on an annual basis and there are heavy penalties in place for those who fail to comply. However, tax-favored foreign trusts (TFFT) are frequently bound by a number of restrictions including information reporting obligations, withdrawal and deposit limitations and Section 6038D annual notification remit on the value of the assets held in each trust. In recognition of the
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