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Form 14654 Texas: What You Should Know
S. Offshore Tax Arrangements Oct 16, 2023 — IRS Form 14654 is used to certify U.S. taxpayer's tax-exempt foreign accounts: Under Rev. Pro. 2012, F.R. 7878: AFFILIATE INTERESTS In General The term “affiliate” means any entity, other than a disqualified individual, which is controlled in any manner which would cause each entity to be treated as a single corporate member of such entity and therefore for purposes of the Code, has the same tax attribute treatment. Determining whether an individual can be treated as an “affiliate” for purposes of applying section 877 is not possible. To qualify for tax-exempt status under this program, an entity is required to (1) have a “connected person” relationship with each foreign trust, and (2) meet all other requirements of the code. A foreign trust is controlled in any manner which would cause each such trust to be treated as a single corporate member of the foreign trust. The Internal Revenue Code provides that for any trust, the Secretary can determine whether an American is an “affiliate” for purposes of applying section 719 if (1) two or more trustees or representatives of the trust are American citizens, (2) the trusts are established for the exclusive benefit of a single U.S. person, and (3) the trust is reasonably believed to be operated directly and substantially in the United States. However, to be considered “operated” in the United States, these requirements do not apply to a foreign trust if at least 80 percent of its gross revenue is derived in the United States. Citizenship test Nonresidents The citizenship test requires: (1) that: (a) at all times while controlled, directly or indirectly, by a U.S. person, each foreign trust that is a beneficiary of a U.S. trust established to avoid U.S. tax has been operated in the United States to enable the U.S. person to qualify as an American, and (b) there are no transactions, arrangements, or relationships with other trusts that are not substantially related to the purpose of the U.S. trust; If any of the conditions above are not met, the foreign trust is deemed to be operated for the exclusive benefit of the U.S.
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