Tax laws are created by Congress, with the Internal Revenue Service (“IRS”) often required to add details by issuing regulations, Revenue Procedures, Notices, and the like. Sometimes though, input from those two sources is not enough; courts must intervene to address voids in or disagreements about the rules. Unfortunately, courts cannot render decisions on important issues if the government is unwilling to subject its behavior to judicial scrutiny. In other words, taxpayers cannot obtain critical answers when the government forces issues to litigation and then surrenders prematurely. That is exactly what has occurred recently with conflicts over foreign gifts and trusts. These issues, which might have been obscure decades ago, are becoming increasingly common and worth a closer look.
Duties Triggered by Foreign Gifts and Trusts
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