Serbinski Accounting Firms

All the points you raise are good ones. But in the absence of any clear statement from the IRS, I think my takeaway is that Americans living in Canada should avoid TFSAs like the plague until an 8891-like clarification is made available. The donation space accrues over the years, so if someone sets ...

But a bank is not a person. The definition clearly states that the assets are help by a person for another person. Do the CRA and the IRS even have the same definition of what a trust is? While the TFSA may be a "trust" by the CRA's definition, that doesn't mean it meets the IRS definition. Again ...

Does anyone have a reference in which the IRS specifically states that TFSAs are to be treated as trusts (i.e. a 3520 must be filed)? I can't find it, but I did find this IRS definition of a trust:

http://www.irs.gov/charities/article/0,,id=96116,00.html

"In general, a trust is a relationship in ...