Jurisdictions: trust law and U.S. reporting
24 jurisdictions, each with a detailed guide to its trust legislation, regulator, reporting framework and legal system, written for U.S. citizens and built from official sources.
How the guides are organized
Each jurisdiction has one overview guide, and most also have separate pages on trust legislation, types of trusts, regulation and licensing, taxation of trusts, reporting and information exchange, the U.S. treaty position and the courts.
No page ranks, scores or compares jurisdictions, and none says that one place suits a person better than another.
Reference table
| Jurisdiction | FATCA agreement entry (Treasury table) | U.S. income tax treaty documents (IRS list) |
|---|---|---|
| Cook Islands | Not listed in the Treasury table | No comprehensive U.S. income tax treaty listed by the IRS |
| Nevis (Saint Kitts and Nevis) | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Belize | Not listed in the Treasury table | No comprehensive U.S. income tax treaty listed by the IRS |
| British Virgin Islands | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Bahamas | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Bermuda | Model 2, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Jersey | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Guernsey | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Isle of Man | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Liechtenstein | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Switzerland | Model 2 in force; Model 1 signed | IRS-listed treaty documents |
| Singapore | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Hong Kong | Model 2, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Mauritius | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Seychelles | Model 1, Signed | No comprehensive U.S. income tax treaty listed by the IRS |
| Malta | Model 1, In Force | Listed by the IRS |
| Cyprus | Model 1, In Force | Listed by the IRS |
| Cayman Islands | Model 1, In Force | No comprehensive U.S. income tax treaty listed by the IRS |
| Canada | Model 1, In Force | Listed by the IRS |
| United Kingdom | Model 1, In Force | Listed by the IRS |
| New Zealand | Model 1, In Force | Listed by the IRS |
| DIFC (Dubai International Financial Centre) | Model 1, In Force (United Arab Emirates) | No comprehensive U.S. income tax treaty listed by the IRS |
| Austria | Model 2, In Force | Listed by the IRS |
| Portugal | Model 1, In Force | Listed by the IRS |
All jurisdictions
Cook IslandsCook Islands trustee licensing, information exchange and court administration, with the U.S. foreign trust reporting rules that apply to U.S. citizens.Nevis (Saint Kitts and Nevis)Nevis trust legislation, trustee roles, provider licensing, local tax provisions and information exchange, with the U.S. reporting rules for citizens.BelizeBelize trust law sets rules for trust creation, administration, trustee duties and registration, alongside local tax treatment and U.S. reporting regimes.British Virgin IslandsBritish Virgin Islands trust legislation and trustee roles are covered with licensing and tax treatment, alongside reporting rules relevant to U.S. citizens.BahamasBahamas trust legislation, trustee roles and local tax provisions, with the U.S. reporting rules that apply to U.S. citizens who hold a foreign trust.BermudaA reference for U.S. citizens on Bermuda trust legislation, trustee licensing, information exchange, U.S. reporting, court structure and residence certificates.JerseyJersey trust legislation, trustee roles, regulation, tax treatment and reporting, with the U.S. foreign trust reporting rules that apply to U.S. citizens.GuernseyGuernsey trust service licensing and CRS and FATCA reporting for U.S. citizens, with the IRS requirements for owners and beneficiaries of foreign trusts.Isle of ManA reference for U.S. citizens covering Isle of Man trustee legislation, fiduciary licensing, financial information exchange and federal foreign trust reporting.LiechtensteinLiechtenstein trusts for U.S. citizens: trustee oversight, legislation, FATCA status and courts, with the IRS trust classifications and reporting duties.SwitzerlandSwitzerland's published trustee licensing rules, its financial information exchange and the IRS foreign trust reporting that applies, set out in one place.SingaporeSingapore trust business licensing and tax rules, with its CRS and FATCA frameworks and the IRS reporting that applies to U.S. citizens with foreign trusts.Hong KongA reference for U.S. citizens covering Hong Kong trust-related licensing, profits tax, financial account information exchange and IRS foreign trust reporting.MauritiusA reference for U.S. citizens on Mauritius trust legislation, trustee roles, licensing, records, reporting frameworks, U.S. forms and residence permits.SeychellesA reference guide for U.S. citizens covering Seychelles trust legislation, trustee roles, registration, tax duties, information exchange and U.S. reporting.MaltaMalta trust regulation, tax administration and information exchange, with the U.S. foreign trust reporting rules for U.S. citizens who use a Maltese trust.CyprusCyprus trust registration and fiduciary licensing, with U.S. foreign trust reporting and the immigration residence routes that matter to U.S. citizens.Cayman IslandsCayman Islands trust legislation, trustee licensing and tax provisions, with the U.S. reporting frameworks that apply to U.S. citizens who use a Cayman trust.Canada trusts, registered accounts and U.S. reportingCanada trusts and registered accounts explained for a U.S. citizen, including Canadian filing rules, U.S. classification, treaty questions and reporting duties.United Kingdom trusts and U.S. reporting requirementsUnited Kingdom trust guidance for a U.S. citizen, covering local taxation, inheritance tax residence rules, U.S. reporting duties and treaty considerations.New Zealand trusts and U.S. reporting requirementsNew Zealand trust guidance for a U.S. citizen, covering local registration, annual returns, trust classification, and separate U.S. tax reporting obligations.DIFC trusts and foundations for U.S. reporting purposesA U.S. citizen guide to DIFC trusts and foundations, explaining local legal scope, U.S. tax classification, reporting duties and essential planning documents.Austria private foundations and U.S. reporting requirementsAn Austrian private foundation raises local tax questions and separate U.S. reporting duties for a U.S. citizen who contributes property or receives a payment.Portugal residence permits and U.S. reporting requirementsPortugal residence permits, investment conditions, trust classification and U.S. reporting duties explained for a U.S. citizen considering a move to Portugal.
Related pages
Sources and data notes
- U.S. Department of the Treasury, Foreign Account Tax Compliance Act: agreements and understandings by jurisdiction. https://home.treasury.gov/policy-issues/tax-policy/foreign-account-tax-compliance-act. Retrieved . Source of the FATCA agreement column.
- Internal Revenue Service, United States income tax treaties, A to Z. https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z. Retrieved . Source of the treaty column.
Dates in this block record when each source was read for this page.