Internal Revenue Code (Title 26 U.S.C.)
26 U.S.C. § 684
Recognition of gain on certain transfers to certain foreign trusts and estates
# (a) In general
Except as provided in regulations, in the case of any transfer of property by a United States person to a foreign estate or trust, for purposes of this subtitle, such transfer shall be treated as a sale or exchange for an amount equal to the fair market value of the property transferred, and the transferor shall recognize as gain the excess of— (1) the fair market value of the property so transferred, over (2) the adjusted basis (for purposes of determining gain) of such property in the hands of the transferor.
# (b) Exception
Subsection (a) shall not apply to a transfer to a trust by a United States person to the extent that any person is treated as the owner of such trust under section 671.
# (c) Treatment of trusts which become foreign trusts
If a trust which is not a foreign trust becomes a foreign trust, such trust shall be treated for purposes of this section as having transferred, immediately before becoming a foreign trust, all of its assets to a foreign trust.
Source: view the official text
Nearby sections (25 sections)
- 671 · Trust income, deductions, and credits attributable to grantors…
- 672 · Definitions and rules
- 673 · Reversionary interests
- 674 · Power to control beneficial enjoyment
- 675 · Administrative powers
- 676 · Power to revoke
- 677 · Income for benefit of grantor
- 678 · Person other than grantor treated as substantial owner
- 679 · Foreign trusts having one or more United States beneficiaries
- 681 · Limitation on charitable deduction
- 682 · [§682. Repealed. Pub. L. 115–97, title I, §11051(b)(1)(C), Dec.…
- 683 · Use of trust as an exchange fund
- 684 · Recognition of gain on certain transfers to certain foreign…
- 685 · Treatment of funeral trusts
- 691 · Recipients of income in respect of decedents
- 692 · Income taxes of members of Armed Forces, astronauts, and victims…
- 701 · Partners, not partnership, subject to tax
- 702 · Income and credits of partner
- 703 · Partnership computations
- 704 · Partner's distributive share
- 705 · Determination of basis of partner's interest
- 706 · Taxable years of partner and partnership
- 707 · Transactions between partner and partnership
- 708 · Continuation of partnership
- 709 · Treatment of organization and syndication fees