Tax Basis of like-kind gifts to a U.S. "foreign Trust"

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Not A Clue

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Jan 17, 2022, 10:49:02 AMJan 17
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U.S. foreign trust = a trust governed by U.S. law but treated as a foreign trust for tax purposes.

Normally, when a donor/settlor transfers securities to a donee/trust, it is valued at the average of the day's high and low -- on the day that the securities leave the donor's account.

However, if the gift is to a foreign trust, it is a deemed sale by the donor/settlor -- I assume at the same method of valuation as above. Does that mean that the basis to the trust is the deemed sale value recognized by the settlor? And the trust's holding period start on the deemed sale valuation date?

If I am correct, can someone point me to the IRS publication, IRC or regulations on the point re basis to donee?

Also, does the valuation date stays the same (the day that the security leaves the donor's account) even if it takes 10-15 days before it arrives at the donee's account?

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