Section 1.679-0 - Outline of major topicsThis section lists the major paragraphs contained in §§ 1.679-1 through 1.679-7 as follows:
§ 1.679-1 U.S. transferor treated as owner of foreign trust.(b) Interaction with sections 673 through 678.§ 1.679-2 Trusts treated as having a U.S. beneficiary.(a) Existence of U.S. beneficiary.(2) Benefit to a U.S. person (ii) Certain unexpected beneficiaries.(3) Changes in beneficiary's status.(4) General rules. (i) Records and documents.(b) Indirect U.S. beneficiaries. (1) Certain foreign entities.(2) Other indirect beneficiaries.(c) Treatment of U.S. transferor upon foreign trust's acquisition or loss of U.S. beneficiary. (1) Trusts acquiring a U.S. beneficiary.(2) Trusts ceasing to have a U.S. beneficiary.§ 1.679-3 Transfers.(b) Transfers by certain trusts.(c) Indirect transfers. (1) Principal purpose of tax avoidance.(2) Principal purpose of tax avoidance deemed to exist.(3) Effect of disregarding intermediary.(iii) Effect on intermediary.(d) Constructive transfers.(e) Guarantee of trust obligations.(3) Principal repayments.(f) Transfers to entities owned by a foreign trust.§ 1.679-4 Exceptions to general rule. (b) Transfers for fair market value. (2) Special rule. (i) Transfers for partial consideration.(c) Certain obligations not taken into account.(d) Qualified obligations. (3) Obligations that cease to be qualified.(4) Transfers resulting from failed qualified obligations.(6) Principal repayments.§ 1.679-5 Pre-immigration trusts. (b) Special rules. (1) Change in grantor trust status.(2) Treatment of undistributed income.§ 1.679-6 Outbound migrations of domestic trusts.(b) Amount deemed transferred.§ 1.679-7 Effective dates. T.D. 8955, 66 FR 37889 , July 20, 2001