Nov 1, 2010 12:00 PM

Bringing It Home

U.S. planning for existing foreign non-grantor trusts

Planning for an existing foreign non-grantor trust that has one or more U.S. beneficiaries presents complex challenges for trustees and professional advisors. Merely understanding the relevant U.S. tax and reporting rules is daunting enough. But, trustees and advisors must proceed further and incorporate these difficult rules into the overall fiduciary decision-making process on appropriate investment and distributional policies for the trust.1 While abundant literature exists on the details of the U.S. tax rules applicable to a foreign non-grantor trust,2 little or no guidance is available regarding how the U.S. tax rules tend to interact over time with a trust's investment allocation and distributional policies, or whether any opportunities or pitfalls that exist are significant or relatively small.3

We'll introduce a quantitative analysis of foreign non-grantor trusts and investigate the interaction of investment allocation, currency selection, distributional policy and U.S. tax rules in the context of a case study. Our research investigates tax-effective methods for transferring wealth from a foreign trust to U.S. beneficiaries.4

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2010 Tax Act News Industry Trends Surveys

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