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

Unfortunately, all goods things
come to an end . . .
• Grantor trust status “terminates” at the death of
the grantor.
• At that point, the trust “springs into existence”
and the normal rules of trust accounting apply:
• Trust is taxable owner of income and assets.
• Distributions are taxable to the beneficiary.
• Foreign trust beneficiaries are subject to throwback.
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