Foreign Trusts For US Family Members: Use of Section 645 Election
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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Come Again?<br />
• Confiscatory Regime Designed to <strong>For</strong>ce<br />
Distributions from Non-Grantor <strong><strong>For</strong>eign</strong> <strong>Trusts</strong><br />
for <strong>US</strong> Beneficiaries<br />
• All Distributions <strong>of</strong> “Accumulated Income” are<br />
taxed at (a) Ordinary Income Rates and (b)<br />
Subject to an Interest Charge for Failing to Pay<br />
Tax in Prior Years. . . OUCH!!!<br />
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