Treasury Regulations · 26 CFR
§ 1.679-0. Outline of major topics.
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
- Cross-references
- cites 1 Code section and 7 regulations; cited by 0
This section lists the major paragraphs contained in §§ 1.679-1 through 1.679-7 as follows:
(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.
- Issued by T.D. 8955 (66 FR 37889)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Grantors and others treated as substantial owners
Nearby sections
- § 1.678(a)-1 Person other than grantor treated as substantial owner; general rule.
- § 1.678(b)-1 If grantor is treated as the owner.
- § 1.678(c)-1 Trusts for support.
- § 1.678(d)-1 Renunciation of power.
- § 1.679-0 Outline of major topics.
- § 1.679-1 U.S. transferor treated as owner of foreign trust.
- § 1.679-2 Trusts treated as having a U.S. beneficiary.
- § 1.679-3 Transfers.
- § 1.679-4 Exceptions to general rule.