Michael Karlin was published in the Journal of International Taxation with an article entitled, “Foreign Trusts and Gifts - It's Getting Warm Offshore.” The article explores Notice 97-34, which was published by the IRS in June 1997 and sought to provide guidance regarding the new foreign trust and foreign gift reporting provisions contained in the Small Business Job Protection Act of 1996, as well as proposed regulations under section 672(f) and 7701(a)(30).
Download PDF