Is able to exercise primary jurisdiction over the administration of the trust; and 2) One or more U.S. fiduciaries have the authority to control all substantial decisions of the trust. Stock Ownership in a Foreign Corporation If stock in a foreign corporation is transferred by gift or bequest to a U.S. Otherwise, the beneficiary can compute a foreign tax credit on Form 1116 of Form 1040. Foreign tax credits offset U.S. taxes attributable to foreign income in the individual's tax return. If there is no positive income, as in the case of a rental loss, the foreign taxes may be taken as an itemized deduction. Under the stock attribution rules for determining whether a foreign corporation is a CFC, stock ownership is attributed from an individual's spouse, children, grandchildren and parents who are also shareholders. If a nonresident shareholder is a spouse, child, grandchild, or grandparent of the U.S.
The threshold amount varies with the type of donor. If the gift is from a nonresident alien or a foreign estate, reporting is only required if the total amount of gifts from the nonresident alien or foreign estate is more than 100,000 (plus an inflation adjustment) for the tax year.
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Gift splitting is not available to foreign nationals not domiciled in the United States. Gifts to U.S. citizen spouses are free of gift tax. Gifts of up to 100,000 per year to a non-U.S.