reportable event
(A)The term “reportable event” means— (i)the creation of any foreign trust by a United States person, (ii)the transfer of any money or property (directly or indirectly) to a foreign trust by a United States person, including a transfer by reason of death, and (iii)the death of a citizen or resident of the United States if— (I)the decedent was treated as the owner of any portion of a foreign trust under the rules of subpart E of part I of subchapter J of chapter 1, or (II)any portion of a foreign trust was included in the gross estate of the decedent. (B) (i)Subparagraph (A)(ii) shall not apply to any transfer of property to a trust in exchange for consideration of at least the fair market value of the transferred property. For purposes of the preceding sentence, consideration other than cash shall be taken into account at its fair market value and the rules ofshall apply. (ii)Subparagraph (A) shall not apply with respect to a trust which is— (I)described in section 402(b), 404(a)(4), or 404A, or (II)determined by the Secretary to be described in section 501(c)(3).