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

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

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Case Study – A Representative <strong>Family</strong><br />

• <strong><strong>For</strong>eign</strong> <strong>Family</strong> with Resident Aliens in the U.S.<br />

• Substantial Off-Shore Wealth<br />

• Primary Goal – To find a tax-effective means <strong>of</strong><br />

transferring wealth to U.S. family members<br />

• Long-term solution<br />

• Minimize or eliminate U.S. and foreign transfer taxes<br />

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