A release from the Office of Chief Counsel clarifies the trustee requirement of Temp. Treas. Reg. § 1.892-2T(c)(1)(ii).
The release concludes that the requirement is satisfied if: (1) as a matter of organization, the majority of trustees of the trust are either government employees or persons appointed by the foreign government, and (2) as a matter of operation, all substantial actions of the trust are approved by a majority of the trustees that are either government employees or persons appointed by the government.
This memorandum addresses the trustee requirement of Temp. Treas. Reg. §1.892-2T(c)(1)(ii). This advice may not be used or cited as precedent.
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