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Treasury Regulations · 26 CFR

§ 1.679-0. Outline of major topics.

In effect eCFR current as of October 15, 2026

Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

Regulation under 26 U.S.C. § 679

Cite as 26 CFR § 1.679-0

At a glance

Read from the text and its source citation. Not part of the regulation.

Status
In the current eCFR
Issued
July 20, 2001 by T.D. 8955
Issued under
26 U.S.C. § 679
Length
371 words · about 2 min to read

This 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.

(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.

§ 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.

§ 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.

(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.

§ 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.

§ 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.

§ 1.679-6 Outbound migrations of domestic trusts.

(a) In general.

(b) Amount deemed transferred.

(c) Example.

§ 1.679-7 Effective dates.

(a) In general.

(b) Special rules.

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

Cross-references

Computed from the citations in the text of 26 CFR.

Code sections it cites

Regulations it cites

Amendment history

From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.

  1. Issued by T.D. 8955 (66 FR 37889)

Where it sits in 26 CFR

  1. Subchapter A Income tax
  2. Part 1 Income taxes
  3. Grantors and others treated as substantial owners

Nearby sections