26 U.S.C. § 684 — Recognition of gain on certain transfers to certain foreign trusts and estates
submitted 29 years ago by Pub. L. 105-34 to r/title-26-INTERNAL-REVENUE-CODE · 177 words · no verdicts yet
A translation hasn’t been published for this section yet. The official text below is complete and authoritative.
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—
the fair market value of the property so transferred, over
the adjusted basis (for purposes of determining gain) of such property in the hands of the transferor.
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.
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 credit: (Added Pub. L. 105–34, title XI, § 1131(b), Aug. 5, 1997, 111 Stat. 978; amended Pub. L. 107–16, title V, § 542(e)(1)(A)–(C), June 7, 2001, 115 Stat. 84, 85; Pub. L. 111–312, title III, § 301(a), Dec. 17, 2010, 124 Stat. 3300.)
- 1997Enacted · Pub. L. 105-34 · 111 Stat. 978
- 2001Amended · Pub. L. 107-16 · 115 Stat. 84, 85
- 2010Amended · Pub. L. 111-312 · 124 Stat. 3300
A history note hasn’t been published yet. The record shows enactment by Pub. L. 105-34 on 1997-08-05.
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