Form 4970 and Form 1041 Schedule J Accumulation Tax: Reporting Distributions From Foreign Trusts
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with guidance on calculating trust accumulation distributions for beneficiaries of foreign trusts. The panel will detail the computations required to complete Schedule J of Form 1041. The panel will discuss the interdependence between Schedule J and the reporting of accumulation distributions on Form 4970 of beneficiaries’ individual tax returns.
Outline
- Default U.S. tax treatment of foreign non-grantor trusts with U.S. beneficiaries
- Throwback tax rules on distributions from UNI to U.S. beneficiaries
- Filing requirements and tax calculations
- Calculated/reported on Form 1041 Schedule J
- Accumulation distributions
- Throwback years and ordinary income accumulation (Part II)
- Taxes on undistributed net income (Part III)
- Long-term capital gains alternative tax election
- Allocation to beneficiaries (Part IV)
- Calculated/reported on Form 4970
- Income average and computation years (Part I)
- Calculating tax on accumulation distribution (Part II)
- Cross-referencing to Form 4970 and Form 1041
- Other foreign reporting requirements
Benefits
The panel will discuss these and other important topics:
- Identifying income that must be treated as UNI
- Calculating tax on distributions made out of UNI to a U.S. beneficiary on Form 4970 Part II
- Methodology for computing “throwback” taxes and reporting on Schedule J Part III
- Impact of electing alternative tax on long-term capital gains held by foreign trust
Faculty
Jack R. Brister, TEP
Managing Member
International Wealth Tax Advisors
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset... | Read More
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures which include foreign trusts, estates and foundations that have a U.S. connection, as well as foreign companies wanting to do business in the U.S. He also specializes in foreign investment in U.S. real property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures, FATCA registration, executives working and living abroad and annual reporting. He has been widely published, in addition to speaking at numerous international engagements.
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Alicea Castellanos, CPA, TEP, N.P.
CEO & Founder
Global Taxes
Ms. Castellanos is the CEO and Founder of Global Taxes LLC. She provides personalized U.S. tax advisory and compliance... | Read More
Ms. Castellanos is the CEO and Founder of Global Taxes LLC. She provides personalized U.S. tax advisory and compliance services to high net worth families and their advisors. Ms. Castellanos has more than 20 years of experience. Prior to forming Global Taxes, she founded and oversaw operations at a boutique tax firm, worked at a prestigious global law firm and CPA firm. Ms. Castellanos specializes in U.S. tax planning and compliance for non-U.S. families with global wealth and asset protection structures which include non-U.S. trusts, estates and foundations that have a U.S. connection. She also specializes in foreign investment in U.S. real estate property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures/tax amnesties, FATCA registration, and foreign companies wanting to do business in the U.S. Ms. Castellanos is fluent in Spanish and has a working knowledge of Portuguese. She is an active full member of the Society of Trusts & Estates Practitioners (STEP), the New York State Society of Certified Public Accountants (NYSSCPAs), the American Institute of Certified Public Accountants (AICPA), the International Fiscal Association (IFA), a member of Clarkson Hyde Global, a world-wide association of accountants, auditors, tax specialists and business advisors and the International Advisory Experts (IAE). Ms. Castellanos has chaired the annual NYSSCPA International Tax Conference for 3 years in a row. Distinctly, in 2020, she was awarded with a prestigious NYSSCPA Forty Under 40 Award. Ms. Castellanos was selected as someone that has notable skills and is visibly making a difference in the accounting profession. She has also been recognized as a leading expert for Tax advice and she has been invited to join Advisory Excellence, as their exclusively recommended tax expert in the USA.
In 2021, Ms. Castellanos was the Gold Winner of Citywealth's 2021 Powerwomen Awards in the category USA - Woman of the Year - Business Growth (Boutique).
In 2022, she was the Silver Winner of Citywealth's 2022 Powerwomen Awards in the category USA - Woman of the Year - Business Growth (Boutique).
Global Taxes and Ms. Castellanos received a nomination for the Magic Circle Awards 2022 edition. For Global Taxes as Accountancy Firm of the year - US and for Alicea Castellanos as the Accountant of the year category.
She was selected by Citywealth as one of the Top 10 Accountants of 2021 serving the Ultra High-Net-Worth Individual (UHNW) segment of the market. The members of the list were selected through thorough independent research undertaken by the editorial team who took into consideration both peer and client feedback.
Furthermore, Ms. Castellanos is currently listed in the Global Elite Directory 2022-23, which is an annual exclusive directory of the world's elite lawyers and outstanding wealth advisors advising ultra-high net-worth clients.
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David Silver, CPA, TEP
Senior Manager
MBAF
Mr. Silver has experience with transactional planning including due diligence, operational and structural analysis. He... | Read More
Mr. Silver has experience with transactional planning including due diligence, operational and structural analysis. He provides tax, accounting, and consulting services to international and domestic corporations, partnerships, and high net worth individuals. He’s been involved in Trust and Estate planning for U.S. beneficiaries of foreign trusts and foreign beneficiaries of U.S. trusts. He also assists clients with pre-immigration, expatriation, and tax structuring to achieve maximum worldwide income and estate tax efficiency. He works with high net worth individuals and organizations in various industries.
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