U.S. transferor
(1) U.S. transferor. The term U.S. transferor means any U.S. person who makes a transfer (as defined in 1.679-3) of property to a foreign trust. (2) U.S. person. The term U.S. person means a United States person as defined in section 7701(a)(30), a nonresident alien individual who elects under section 6013(g) to be treated as a resident of the United States, and an individual who is a dual resident taxpayer within the meaning of 301.7701(b)-7(a) of this chapter. (3) Foreign trust. Section 7701(a)(31)(B) defines the term foreign trust. See also 301.7701-7 of this chapter. (4) Property. The term property means any property including cash. (5) Related person. A person is a related person if, without regard to the transfer at issue, the person is (i) A grantor of any portion of the trust (within the meaning of 1.671-2(e)(1)); (ii) An owner of any portion of the trust under sections 671 through 679; (iii) A beneficiary of the trust; or (iv) A person who is related (within the meaning of section 643(i)(2)(B)) to any grantor, owner or beneficiary of the trust. (6) Obligation. The term obligation means any bond, note, debenture, certificate, bill receivable, account receivable, note receivable, open account, or other evidence of indebtedness, and, to the extent not previously described, any annuity contract.