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Internal Revenue Code: Sections 671-679 of the IRC relating to trust taxation and treatment of foreign trust beneficiaries

FATCA: Foreign Account Tax Compliance Act - Requires reporting of foreign financial accounts and offshore assets

Treasury Regulations: Federal regulations providing specific guidance on the treatment of foreign trusts and beneficiaries

Bank Secrecy Act: Requires reporting of certain financial transactions, particularly those with foreign elements

Uniform Trust Code: Model law adopted by many states governing trust administration and modification, including rules for trust variations

State Trust Laws: State-specific legislation governing trust administration, modification, and beneficiary rights

Common Law Principles: Established case law and legal principles regarding trust modifications and variations

Rule Against Perpetuities: Common law rule limiting the duration of trust provisions, may affect variation terms

Beneficiary Notice Requirements: State-specific rules regarding mandatory notification to beneficiaries of trust modifications

International Tax Treaties: Bilateral agreements between the US and other countries affecting taxation of trust distributions to foreign beneficiaries

Common Reporting Standard: International framework for exchange of tax information, relevant when excluding foreign beneficiaries

Equal Protection Clause: Constitutional requirement ensuring equal treatment under the law, may affect validity of excluding foreign beneficiaries

Due Process Requirements: Constitutional protections ensuring fair procedures in modifying beneficiary rights