REPORTING REQUIREMENTS: FOREIGN NON-GRANTOR TRUST – US BENEFICIARIES

Here are the key considerations for US tax filings related to Foreign Non-Grantor Trusts

  • 1. Form SS-4 – Application for Employer Identification Number (EIN)

    Foreign trusts with US beneficiaries or US owners may need an EIN to fulfil reporting requirements, such as reporting trust distributions or ownership interests to the IRS.

  • 2. US Agent for the Foreign Trust

    It can be beneficial for a foreign trust to appoint a US agent to facilitate communication with the IRS, ensure proper reporting and minimise the trust documentation which may be required to be submitted to IRS.

  • 3. Form 3520

    US beneficiaries who receive distributions from a Foreign Non-Grantor Trust may be required to file Form 3520, “Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts.

  • 4. US Income Tax Return (Form 1040 or 1040NR)

    US beneficiaries may need to report income received from the Foreign Non-Grantor Trust on their individual US income tax returns (Form 1040 for US persons or Form 1040NR for non-residents with US source income).

  • 5. Form 8938

    US taxpayers who have an interest in specified foreign financial assets, including interests in Foreign Non-Grantor Trust, may be required to file Form 8938, “Statement of Specified Foreign Financial Assets.

  • 6. Foreign Bank Account Reporting (FBAR – FinCEN Form 114)

    US persons, including US owners of the foreign trust may have to file FinCEN Form 114 (FBAR) to report financial interests in foreign bank and financial accounts. This includes accounts held by the foreign trust, especially if the trust has signature authority or control over the accounts.

  • 7. Ownership of Foreign Corporations

    If the foreign trust holds an interest in foreign corporations, especially those meeting the criteria of a 'controlled foreign corporation' (CFC) or 'passive foreign investment company' (PFIC), additional reporting may be necessary. Stock ownership by a foreign trust in foreign corporations may be attributed proportionately to U.S. beneficiaries. This attribution can trigger additional tax and reporting obligations for U.S. beneficiaries even if they do not receive distributions from the trust. a. Form 8621 Information Return by a Shareholder of a Passive Foreign Investment Company b. Form 5471 - Information Return of U.S. Persons with Respect to Certain Foreign Corporations