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

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What is a Grantor Trust?<br />

• Generally speaking, a “grantor trust” is a trust<br />

that is treated as owned for U.S. income tax<br />

purposes by the grantor.<br />

• If the grantor is treated as the owner <strong>of</strong> a trust,<br />

then the trust form is disregarded for U.S.<br />

income tax purposes and income, deductions<br />

and credits <strong>of</strong> the trust are attributable to the<br />

grantor.<br />

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