International Trusts with U.S. Resident Beneficiaries

We can assist trustees of trusts which have U.S.-resident beneficiaries to ensure that the trust is managed in a U.S. -compliant manner.

A Non-Grantor Trust should avoid owning PFIC investments (non-U.S. mutual funds) due to the unfavorable U.S. tax treatment of PFICs. A non-U.S.-resident settlor trust (Grantor Trust) with U.S. beneficiaries does not have an issue holding PFICs within it. However, once the settlor dies, the trust is no longer considered a Grantor Trust, and the PFICs within the trust attract onerous US tax exposure.

It is therefore a practical problem for a Grantor Trust to hold PFICs during the settlor ‘s lifetime, as once the settlor dies, the trust  can be in a situation where it is then difficult to dispose of the PFIC without US tax ramifications. A practical solution is for the Grantor Trust to maintain a U.S.-compliant portfolio.

Philip Braude (Investment Marketer) can assist the trustees of trusts with US-resident beneficiaries by providing access to US-compliant investments.

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