On May 8, 2024, the Internal Revenue Service proposed long-awaited regulations relating to foreign gifts and foreign trusts. These proposed regulations largely implement a notice dating back to 1997 and have likely been proposed because of recent developments in which notices have been invalidated for failure to comply with the Administrative Procedures Act requiring public notice and an opportunity for the public to comment (and have those comments carefully considered).
On July 8, the Section of Taxation of the American Bar Association submitted extensive comments on the proposed regulations. Michael Karlin was an active participant in the preparation of the comments. In addition, Michael submitted his own separate comments on the proposed regulations. Both sets of comments are available in the Publications section of our website.
Click here to read Michael Karlin’s letter to the Internal Revenue Service.
