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An abusive scheme toolkit for external stakeholders

Table of contents

1. Introduction
2. Facts
   • Background
   • Basic trust taxation rules
   • Abusive domestic trust schemes
   • Abusive foreign trust schemes
   • Accessing the offshore funds
3. Law and arguments
   • Substance - not form - controls taxation
   • Grantors may be treated as owners of trusts
   • Taxation of non-grantor trusts
   • Transfers to trusts may be subject to estate and gift taxes
   • Personal expenses are generally not deductible
   • A genuine charity must benefit in order to claim a valid charitable deduction
   • Special rules apply to foreign trusts
4. Talking points
5. News releases
6. Trifold available PDF
7. Questions and answers
8. Referrals/contacts
9. Special types of trusts
10. Glossary of trust terms
11. Form 14242, Report Suspected Abusive Tax Promotions or Preparers PDF