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26 U.S.C. § 684

Recognition of gain on certain transfers to certain foreign trusts and estates

United States · Title 26 — INTERNAL REVENUE CODE · Status: effective

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26 U.S.C. § 684, Recognition of gain on certain transfers to certain foreign trusts and estates, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/462652
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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— 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.

Legislative history

The public laws that enacted or amended this section. Tallies are for the whole bill as it passed each chamber — often an omnibus covering far more than this provision — not a vote on this section alone.