US tax treatment of the Liechtenstein trust enterprise (Trust Reg.)

摘要

The US provided guidance on the tax treatment of Liechtenstein Stiftungen (foundations) and Anstalten (establishments). This guidance concludes that Anstalten are generally classified as business entities, and specifically as corporations for US tax purposes, and Stiftungen are generally treated as trusts for US tax purposes. The IRS guidance did not address the US tax treatment of the Treuunternehmen (Trust Enterprise or more commonly known as Trust Reg.), which is the third most common Liechtenstein wealth management vehicle. This article discusses the treatment of a Trust Reg. as a business entity, and more specifically a corporation for US tax purposes.