Michael Karlin's Letter with Comments to the Internal Revenue Service on Regulations Under Sections 643(i), 679, 6039F, 6048, and 6677

In a letter to the IRS, Michael Karlin shares his comments on the May 8, 2024 proposed regulations for sections 643(i), 679, 6039F, 6048, and 6677 on transactions with foreign trusts and information reporting on transactions with foreign trusts and large foreign gifts. His comments address the timing of inheritances, proposed regulation section 1.6048-4(d)(1) – Assumed 10-Year Life of Trust, the default method and domesticated trusts, and pension plans and the definition of “Trust.”