PRESUMPTION THAT FOREIGN TRUST HAS UNITED STATES BENEFICIARY.

SEC. 532. PRESUMPTION THAT FOREIGN TRUST HAS UNITED STATES BENEFICIARY.(a) In General.—Section 679 is amended by redesignating subsection (d) as subsection (e) and inserting after subsection (c) the following new subsection:“(d) Presumption That Foreign Trust Has United States Beneficiary.—If a United States person directly or indirectly transfers property to a foreign trust (other than a trust described in 124 STAT. 114 section 6048(a)(3)(B)(ii)), the Secretary may treat such trust as having a United States beneficiary for purposes of applying this section to such transfer unless such person—“(1) submits such information to the Secretary as the Secretary may require with respect to such transfer, and“(2) demonstrates to the satisfaction of the Secretary that such trust satisfies the requirements of subparagraphs (A) and (B) of subsection (c)(1).”.(b) Effective Date.—The amendments made by this section shall apply to transfers of property after the date of the enactment of this Act.