Foreign trust structures with US beneficiaries: finding income and reportable interests. 15 November 2022

Host group
Host Left
Hosted by
STEP New England
Event Type

One Federal Street, 25th Floor
Boston, MA 02110
United States of America


Lawrence M. Lipoff will discuss foreign entity attribution through foreign trusts to their US beneficiaries. In particular, Larry will address:

  • When a foreign trust owns interests in closely-held foreign companies, hedge funds, and partnerships, how might this impact U.S. beneficiaries and what types of advance planning might be considered?
  • In addition to income tax, what might be required in terms of informational reporting, even including FBARs and soon the Corporate Transparency Act?


Lawrence M. Lipoff, CPA, TEP, CEBS, is a Director in CohnReznick’s Trusts and Estates Practice, based in the firm’s New York office. With 30 years of experience, Larry specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. Larry provides strategic advice to his clients and their closely-held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value.

He is a frequent lecturer and author of articles published through professional forums on topics including 1041/706/709/3520 & 3520-A returns, fiduciary taxation including foreign trusts, international estate planning and administration, fiduciary taxation, grantor charitable lead trusts, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private equity and hedge fund principals and private placement life insurance.

Non-Member Payments:
Guest payments can be made by check payable to STEP Boston and sent c/o Rebecca Tunney, Goulston & Storrs, 400 Atlantic Avenue Boston MA 02110, or by PayPal to [email protected].

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STEP Members - Free
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Non-STEP Members
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