[Code of Federal Regulations]
[Title 26, Volume 8]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.679-0]

[Page 308-309]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.679-0  Outline of major topics.

    This section lists the major paragraphs contained in Sec. Sec. 
1.679-1 through 1.679-7 as follows:

    Sec. 1.679-1 U.S. transferor treated as owner of foreign trust.

    (a) In general.
    (b) Interaction with sections 673 through 678.
    (c) Definitions.
    (1) U.S. transferor.
    (2) U.S. person.
    (3) Foreign trust.
    (4) Property.
    (5) Related person.
    (6) Obligation.
    (d) Examples.

       Sec. 1.679-2 Trusts treated as having a U.S. beneficiary.

    (a) Existence of U.S. beneficiary.
    (1) In general.
    (2) Benefit to a U.S. person
    (i) In general.
    (ii) Certain unexpected beneficiaries.
    (iii) Examples.
    (3) Changes in beneficiary's status.
    (i) In general.
    (ii) Examples.
    (4) General rules.
    (i) Records and documents.
    (ii) Additional factors.
    (iii) Examples.
    (b) Indirect U.S. beneficiaries.
    (1) Certain foreign entities.
    (2) Other indirect beneficiaries.
    (3) Examples.
    (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.
    (3) Examples.

                        Sec. 1.679-3 Transfers.

    (a) In general.
    (b) Transfers by certain trusts.
    (1) In general.
    (2) Example.
    (c) Indirect transfers.
    (1) Principal purpose of tax avoidance.
    (2) Principal purpose of tax avoidance deemed to exist.
    (3) Effect of disregarding intermediary.

[[Page 309]]

    (i) In general.
    (ii) Special rule.
    (iii) Effect on intermediary.
    (4) Related parties.
    (5) Examples.
    (d) Constructive transfers.
    (1) In general.
    (2) Examples.
    (e) Guarantee of trust obligations.
    (1) In general.
    (2) Amount transferred.
    (3) Principal repayments.
    (4) Guarantee.
    (5) Examples.
    (f) Transfers to entities owned by a foreign trust.
    (1) General rule.
    (2) Examples.

                Sec. 1.679-4 Exceptions to general rule.

    (a) In general.
    (b) Transfers for fair market value.
    (1) In general.
    (2) Special rule.
    (i) Transfers for partial consideration.
    (ii) Example.
    (c) Certain obligations not taken into account.
    (d) Qualified obligations.
    (1) In general.
    (2) Additional loans.
    (3) Obligations that cease to be qualified.
    (4) Transfers resulting from failed qualified obligations.
    (5) Renegotiated loans.
    (6) Principal repayments.
    (7) Examples.

                  Sec. 1.679-5 Pre-immigration trusts.

    (a) In general.
    (b) Special rules.
    (1) Change in grantor trust status.
    (2) Treatment of undistributed income.
    (c) Examples.

          Sec. 1.679-6 Outbound migrations of domestic trusts.

    (a) In general.
    (b) Amount deemed transferred.
    (c) Example.

                     Sec. 1.679-7 Effective dates.

    (a) In general.
    (b) Special rules.

[T.D. 8955, 66 FR 37889, July 20, 2001]