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What is Form 3520-A and when does a foreign trust need to file it?
My family has a trust set up in the UK that I'm a beneficiary of. I've been filing Form 3520 to report distributions I receive, but my tax advisor mentioned the trust itself might need to file Form 3520-A. The trust is managed by a UK trustee and has multiple beneficiaries, some of whom are U.S. persons. Who is responsible for filing this form and what happens if the foreign trustee refuses to cooperate?
Related Questions
What is GILTI and how does it affect U.S. shareholders of foreign corporations?
I keep hearing about GILTI in the context of international tax reform. I'm a U.S. person who owns a foreign company, and someone told me I might owe tax on income my foreign company earns even if I never take a dividend. That sounds crazy to me. Can someone explain what GILTI actually is, how it works at a high level, and who it applies to? I want to understand the basics before I talk to my CPA.
I'm a foreign person owning a U.S. LLC — do I need to worry about GILTI?
I'm a non-U.S. resident who owns a single-member LLC in the United States. My LLC provides consulting services to clients in the U.S. and abroad. A friend told me about GILTI and said I should check if it applies to me. But everything I read says GILTI is for U.S. shareholders of foreign corporations. I'm a foreign person owning a U.S. entity — isn't that the opposite? Do I need to worry about GILTI at all, or is this a non-issue for someone in my situation?
How do you calculate GILTI? What are tested income, QBAI, and net DTIR?
I understand GILTI at a high level but I'm struggling with the actual calculation. My CPA mentioned terms like 'tested income,' 'QBAI,' and 'net deemed tangible income return' and I got lost. I own a U.S. holding company that has two CFCs — one is profitable and the other is running at a loss. Can someone walk me through the mechanics of how GILTI is actually computed? And does the loss from one CFC offset the income from the other?
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