Foreign Trusts For US Family Members: Use of Section 645 Election

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BUT . . . the Throwback Rules only apply to . . . FOREIGN NON-GRANTOR TRUSTS; NOT GRANTOR TRUSTS 10
What is a Grantor Trust? • Generally speaking, a “grantor trust” is a trust that is treated as owned for U.S. income tax purposes by the grantor. • If the grantor is treated as the owner of a trust, then the trust form is disregarded for U.S. income tax purposes and income, deductions and credits of the trust are attributable to the grantor. 11
Page 1 and 2: Foreign Trusts For US Family Member
Page 3 and 4: Usual Solution: The Trust • Most
Page 5 and 6: Current Year Income Distributed •
Page 7 and 8: Throwback Rules: Downright Ugly •
Page 9: Come Again? • Confiscatory Regime
Page 13 and 14: U.S. Income Tax Advantages of Forei
Page 15 and 16: Entering Stage Left . . . The “Se
Page 17 and 18: Section 645 Planning - Making the E
Page 19 and 20: In the case of an Estate (Including
Page 21 and 22: And . . . Maybe Even More Exciting
Page 23 and 24: Section 645 Planning: Basis Step-Up
Page 25 and 26: Section 645 Basis-Step Up: Illustra

Foreign Trusts For US Family Members: Use of Section 645 Election

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