A Foreign Trust Investing In The US: ‘Ordinary’ Or ‘Business’ Trust?

reprinted with permission from Global Tax Weekly, Wolters Kluwer by Marc Schwartz and Paul Tadros All Section references are to the US Internal Revenue Code, 1986, as amended and the US Department of the Treasury regulations (collectively, “Code”) promulgated thereunder unless stated otherwise; Unless stated otherwise, the terms “tax” and “taxation” mean income tax; Unless …

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