"Accumulation Distribution" and "Undistributed Net Income" b. Beneficiaries Changing Nationality During the Taxable Year VI.

Gains Recognized on Certain Pre-August 6, 1997 Sales and Exchanges G. Wealth Transfer Taxes on Foreign Transfers to Foreign Trusts Introductory Material A.

Distributions Through Intermediaries (1) Generally (2) When Distribution Through Intermediary Is Deemed Made (3) The Grantor as Intermediary (4) De Minimis Rule (5) Effective Date 2.

Computation of DNI (1) Worldwide Income (2) Capital Gains d.

(Taxation), Georgetown University Law Center (1976); Consulting Counsel; member, Virginia State Bar; BNA Tax Management Advisory Board on Estates, Gifts and Trusts; University of Miami (Heckerling) Estate Planning Institute Advisory Committee; author or co-author, numerous articles and several treatises, including: Tax Planning for Family Wealth Transfers, Generation-Skipping Transfer Taxes: Analysis with Forms (with Carol Harrington & Lloyd Leva Plaine); Structuring Buy-Sell Agreements (with Farhad Aghdami & Mary Ann Mancini); Structuring Estate Freezes After Chapter 14 (with Ron Aucutt); Federal Income Taxation of Estates and Trusts (with Robert Danforth & Norman Lane); Tax Planning With Life Insurance (with Stephan Leimberg) — all published by Warren, Gorham & Lamont/RIA Group; tax editor, Probate Practice Reporter; Fellow, the American College of Trust and Estate Counsel and American College of Tax Counsel; former Chair, Virginia Bar Association Section on Wills, Trusts & Estates; lecturer, numerous Tax and Estate Planning Institutes, including Institutes of the University of Miami (Heckerling Institute), New York University, Georgetown University, Duke University, and the University of Southern California. A.; member, Editorial Board, University of Miami Law Review; Certified Public Accountant, Florida; member, Florida Bar; member, Tax and International Law Sections of the Florida Bar; Adjunct Professor of Law, University of Miami School of Law (1990– ); guest lecturer, University of Miami School of Business Administration; Chairman, Asset Protection Committee of the American Association of Attorney - Certified Public Accountants (2004–present); co-author, 810-2nd T. Foreign Trusts: A Brief Historical Look Introductory Material A.

D., University of Miami (1973, Summa Cum Laude); Shareholder, Law Firm of Donlevy-Rosen & Rosen, P.

The Statutory Exceptions (1) The § 367 Exception (2) The Recognition Election Exception: Former § 1057 2.

Transfers to Certain State-Law Trusts That Are Not Taxed as Trusts for Income Tax Purposes h.

grantor to recognize gain on the transfer of appreciated property to a foreign trust.

beneficiaries of such a trust taxable as the deemed owners. In addition, all accumulation distributions are subject to an interest charge.

Transfers to Charitable or Employee Benefit Trusts e.

Transfers for Fair Market Value (1) Transfers Before February 7, 1995 (2) Transfers After February 6, 1995 (a) Generally (b) Transfers for Partial Consideration (c) Debt Obligations Generally (d) Qualified Debt Obligations (i) Changing the Terms (ii) Principal Payment d.

Court Test (1) Generally (2) Trust Registration (3) Testamentary Trusts (4) Petition to a U. Court (Inter Vivos Trusts) (5) Co-Supervision by U. and Foreign Courts (6) Automatic Migration Clauses (7) Supervision of Administration by Multiple Courts b.