Should Offshore Trusts Stay Offshore – The Long-Term Trust Solution

The first part of this series summarised the US tax rules that subject US beneficiaries of foreign trusts to both a throwback tax regime and an interest charge when they receive distributions of accumulated income from a trust established in a no-tax jurisdiction outside the United States (hereinafter referred to as ‘offshore trusts’) (for further details please see “Should offshore trusts stay offshore – the problems”). The first part of this series also examined planning to quarantine the tainted income, the cleansing distribution method and related drawbacks. August 1, 2019. Download