Michelle Graham authored a Tax Notes article titled "Proposal for Certain Foreign Entities to Be Treated as Trusts." In this article, Michelle Graham proposes an entity classification election that would provide clarity to purpose trusts and other foreign structures such as foundations and nonstock corporations that are functioning as ordinary trusts, and she suggests the addition of two scenarios to satisfy the judicial test for determining whether trusts are domestic or foreign.
LINKS
Click here to read "Proposal for Certain Foreign Entities to Be Treated as Trusts" on the Tax Notes website. (subscription required)
Click the attachment below to read a PDF version of the article.