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Stephen Ziobrowski to Speak at Boston Bar Association Event: "Foreign Trusts: U.S. Income Tax Considerations"

February 11, 2010

Boston partner Stephen Ziobrowski will participate in a five-member panel February 11 on foreign trusts sponsored by the Boston Bar Association's Estate Planning Committee of the Trusts & Estates Section.

About the program:

Offshore trusts are becoming more widely used, as U.S. residents establish offshore trusts for asset protection and other purposes. In addition, non-resident non-citizens who have settled trusts or who are trust beneficiaries are moving to the U.S., marrying U.S. persons, and having children who are U.S. persons. In light of the UBS scandal and the overwhelming response to its offshore voluntary disclosure program, the IRS is focusing increased attention on foreign trusts and compliance with the rules governing them.

This program will demystify the complex U.S. income tax issues involving foreign trusts, including reporting obligations. Failure to comply with these rules can lead to substantial tax problems and possibly penalties. U.S. advisors need to know these rules if they represent U.S. persons who are establishing foreign trusts for estate planning, asset protection, or other purposes. U.S. advisors also need to know these rules if they represent U.S. clients who are or may become beneficiaries of foreign trusts.

Specific Topics will include:

1. Determining whether a trust is foreign or domestic
2. Determining whether a foreign trust is a grantor trust or a nongrantor trust
3. U.S. tax treatment of foreign nongrantor trusts and their beneficiaries
4. Migration of foreign trusts to the U.S.
5. Tax treatment of controlled foreign corporations and passive foreign investment companies held through foreign trusts
For more information or to sign up for this event go to

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