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S., a domestic partnership, a domestic corporation, any estate other than a foreign estate and certain trusts. Section 6012 contains the requirements for when an individual or entity is required to file a U. A domestic trust is a grantor trust if it meets any one of the criteria set forth under sections 671 through 679. A major distinction between the taxation of a foreign trust compared to a U. domestic trust is the inclusion of capital gains and losses in DNI. Federal Income Taxation of Foreign Nongrantor Trusts In a year when a foreign nongrantor trust makes distributions in excess of the current year DNI calculation, the U. beneficiaries will be required to calculate tax due on any part of that distribution which qualifies as an “accumulation distribution.” That is, where a trust has made a distribution in excess of the trust’s current year DNI, the trust either makes a distribution of capital or an accumulation distribution. … continue reading »
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