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This is my written testimony on the 2024 proposed regulations regarding foreign trusts, specifically as they apply to U.S. individuals who own tax-favored employer or foreign government sponsored accounts that provide pension, retirement, or other savings benefits. I also presented oral testimony at the public hearing on the proposed regulations on August 21, 2024. Final…

Original article printed in Tax Notes Federal on February 10, 2025. See The Form 8938 Due Date Defect 2-10-25.  Introduction to the Form 8938 Defect This article exposes a flaw in section 6038D of Form 8938 that makes the penalties for failure to file under section 6038D(d) ineffective, and it calls on the commissioner to…