tag:blogger.com,1999:blog-6398232680738279469.post5993547290285851114..comments2024-03-12T07:30:17.846-07:00Comments on The Tax Times: Foreign Trusts With Individual Trustees Are NFFE's & Are Not Subject to FATCA Reporting.Ronald A. Marini, Esq.http://www.blogger.com/profile/14304486100168506240noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-6398232680738279469.post-68735728013028850002013-02-08T10:42:41.388-08:002013-02-08T10:42:41.388-08:00If this foreign trust has one individual beneficia...If this foreign trust has one individual beneficiary )and no assets, not sure why it was set up years ago), does it have to file a 3520A? <br /><br />By Jeffrey A. Schneider, EA<br />Ronald A. Marini, Esq.https://www.blogger.com/profile/14304486100168506240noreply@blogger.comtag:blogger.com,1999:blog-6398232680738279469.post-54414956347346533932013-02-08T10:12:45.140-08:002013-02-08T10:12:45.140-08:00As NFFEs, small trusts will be subject to passive ...As NFFEs, small trusts will be subject to passive NFFE considerations and should be required to report substantial owners that are specified U.S. persons to U.S. withholding agents. The presumption standards will also have some bearing. Trusts that are professionally managed will still be FFIs but their professional manager will be a FFI and may be a sponsoring FFI so the FATCA compliance burden could fall on the manager, not the trust. Not sure I would say if a single trustee as many small trusts that have co-trustees could still be NFFEs is they are not managed or considered an investment fund. <br /><br />By Jerri LS Langer<br />Ronald A. Marini, Esq.https://www.blogger.com/profile/14304486100168506240noreply@blogger.com