Overview
John S. Kiely spoke at the “Covered Gifts and Bequests From Covered Expatriates: Final Section 2801 Regs” webinar hosted by Strafford on May 22, 2025. This webinar analyzed the final regulations under Section 2801 for trust and estate professionals working with multinational taxpayers.
Key topics included:
- Identifying covered gifts and bequests under Section 2801 and in particular determining whether a distribution from a non-electing foreign trust is partially or entirely subject to the 2801 tax
- Modifications made to the September 2015 proposed regulations
- Filing new Form 708, U.S. Return of Tax for Gifts and Bequests Received from Covered Expatriates
- Record keeping and what to do about the absence of records
- Electing to be treated as a domestic trust for purposes of Section 2801
