Basics of a Foreign Non-Grantor Trust & US Beneficiary

[@robertcarr272]

So... the issue appears to be 'US INCOME' or 'INCOME' distributed to a 'US BENEFICIARY'... yes?

[@esquiregroup]

Yes, this is a key issue, but the U.S. taxation of foreign trusts is quite complex. If you’d like to discuss, please schedule a consultation with me by emailing us at [e-mail]. Thanks!

[@robertcarr272]

Why would not the foreign parents be the foreign grantor/settlor/trustor for the US PERSON beneficiary?

[@esquiregroup]

This is possible and quite typical.

[@robertcarr272]

Whom or who is the 'Foreign situs trust'?

[@esquiregroup]

I don’t understand the question?

[@Reinheit]

26 CFR § 1.402(c)-1

[@robertcarr272]

BTW, whom is the elusive trustee in your scenario?

[@esquiregroup]

Depends. It can be either a professional trustee or a private trust company managed by the family setup by the trust.

[@naturalearththreepointthre2553]

Would like to pick your brain, do you have a email

[@esquiregroup]

[e-mail]