¹The authors website (www.offshorepress.com/AICPA/ ) includes a list of these forms and links to numerous international tax resources.

²A more extensive discussion of 21 of the most commonly used international tax forms is available for AICPA members at www.offshorepress.com/AICPA/taxforms.htm. For each of the forms listed, there is a discussion of who is required to file, the information required, when the form is due, how long it takes to prepare, the nonfiling penalties and other comments.

³See Secs. 911 and 912. Section 350 of S. 1054, the Jobs and Growth Tax Relief Reconciliation Act of 2003, as introduced and passed in the Senate, would have repealed the foreign-earned-income and housing- expense exclusions. However, the House and final versions of the bill did not include the provision. The defeat may have been in large part due to the AICPAs efforts; see www.cpa2biz.com/ResourceCenters/Tax/International/section911.htm. It does not appear likely that this issue will surface again in the near future.

⁴The International Deposit Indemnity Corporation is not a government-supported insurance program.

⁵Investment schemes that purport to offer very high returns and distribute them to early participantsusing money from later participantsare called Ponzi schemes, because they resemble a scheme developed by Charles K. Ponzi; see www.mark-knutson.com. The Grenada Bank scheme has been estimated to have generated over $125 million in deposits; see www.taxnews.com/asp/story/story_print.asp?storyname=4810.

⁶Property held as joint tenants with right of survivorship can be subject to the claims of creditors of either joint owner; see Rosen and Rothschild, Asset Protection Planning, 810-2d T.M.

⁷See www.offshorepress.com/protection/ap9401.htm.

⁸Foreign trusts are at risk if the grantor retains control over the trustee or the assets; see Jacobs and Duke, The Offshore Tax Manual (Offshore Press, Inc., 2d ed. 2002), Part 6, at www.offshorepress.com/offshoretaxmanual.htm.

⁹The income of a foreign trust is not taxable to the grantor if the trust does not have any living U.S. beneficiaries; the income of a foreign corporation is not taxable to the U.S. shareholders unless it is a CFC under Secs. 951964 and it has subpart F income as defined in Sec. 952.

¹⁰See Jacobs, Your Guide to Offshore Variable Annuities (Offshore Press, Inc., 2001) at www.offshorepress.com/osva-info.htm.

¹¹See id.

¹²See www.irs.gov/pub/irs-pdf/f8854.pdf.

¹³See www.irs.gov/pub/irs-pdf/f1040c03.pdf.