id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-447	Rabitz, Steven W.	An Overview Concerning Certain Recent Changes for Foreign Compensatory Trusts: 402(b) Trusts, Grantor Trusts and "Rabbi" Trusts	2022	53	.pdf	application/pdf	22911	846	47	Because section 679 is the only statutory provision that explicitly applies to foreign grantor trusts (other than section 672(f)), and because Congress specifically excluded section 402(b) arrangements from the application of section 679, one could read all of the provisions taken in their entirety to mean that Congress did not intend for the grantor trust rules to apply to foreign nonexempt employees' trusts at all. In February 1999, and again in August 1999, the Service issued certain final regulations affecting foreign trusts.	cache/ftr-447.pdf	txt/ftr-447.txt