Write 1 page with APA style on International Tax and Estate Planning Benchmark Assignment 5. International Law and E Planning al Affiliation) Answer to question one Non-resident alien individuals who are involved in various businesses in the United States or those who have income from the United States sources must fill an income return on form 1040NR (Granwell, 2011). Chapter 1, section 10.02, page 1.

Answer to question two

A foreign partnership must generally fill an information return on form number 1065 if it has income from the United States sources or is engaged in the United States business. Chapter 1, section 10.04, page 1.

Answer for question three

A non-resident alien files a gift tax return on form number 709 if the gift is made of property located in the United States. There is no requirement to return gifts of intangible property. Chapter 1, section 10.05, page 1

Answer to question four

A foreign corporation with income subject to the United States active business must fill a tax return on form 1120F. Chapter 1, section 10.04, page 1

Answer to question five

The amount does not exceed sixty thousand dollars and the type of tax is excise tax. These are the requirements with respect to payment of premises with respect to offshore life insurance (Dumont & Lawrence, 2012).

Answer to question six

For legal and tax purposes, the beneficial owner of the policy investment must be the insurance carrier (Granwell, 2011).

Answer to question seven

The name of the exemption under the 1933 securities act available for offshore including the offshore life insurance is the Reg S exemption.

Answer to question eight

The main premium payments requirements with respect to non-modified endowment are the excise tax and the tax imposed by I.R.C, section 4371.

Answer to question nine

The number of portfolio or segregated accounts for establishment to ensure meeting of the diversification requirements for a viable life insurance policy under internal revenue code section 817 (h) is not specific (Dumont & Lawrence, 2012). There should be creation of one or more segregated portfolios in order to segregate its various assets and liabilities. Although a segregated portfolio must be distinct, this does not mean that it is a separate entity from the insurer.

Answer to question ten

Yes, this is because it is a vital concept during the implementation of this principle, which is offshore life insurance or offshore annuity contract (Granwell, 2011).


Dumont, R., & Lawrence, R. (2012). International estate & tax planning, 2012. New York, N.Y.: Practising Law Institute.

Granwell, A. (2011). International tax planning for the U.S. multinational corporation. New York, N.Y. (810 7th Ave., New York 10019): Practising Law Institute.

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