Prologue – The “Take Away” And Summary For Americans Abroad
A Mexico Land TRUST, is not a FOREIGN TRUST for IRS purposes – ("cannot be what it isn't"). But, a Liechtenstein “Stiftung” – private FOUNDATION with no reference to the word TRUST is a FOREIGN TRUST for IRS penalty purposes – ("would be what it isn't"). https://t.co/3qaB8NWrnF pic.twitter.com/iHkZMP8iAS
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 16, 2022
The general message is contained in the above twitter thread. Americans abroad are likely to have financial involvements with a number of different kinds of “entities” that are “local” to them and “foreign to the United States. Examples may include: pension plans, tax advantaged savings plans, small business corporations and more. The descriptive title of these “entities” is irrelevant to their classification under US tax rules.