US taxation of Foreign Trusts

A trust is a fiduciary arrangement that allows a third party, or trustee, to hold properties on behalf of a beneficiary or beneficiaries.  Trusts allow for the ownership of certain assets to be transferred from the grantor (one who creates the trust and funds it with assets) and controlled by a trustee for the benefit of a beneficiary. Whether a grantor, a trust beneficiary or the trust is subject to any US income tax is determined by

  • whether the trust is a US domestic or foreign trust;

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US Estate Tax for Nonresident Alien

For estate tax purposes, a person is a “resident decedent” if the person is “domiciled” in the U.S. at the time of his or her death. The estates of resident aliens follow the same rules and regulations as do the estates ofU.S.citizens to determine estate tax liability. However, the estates of nonresident aliens are taxed differently.

U.S. estate tax for NRA

while U.S persons are subject to estate and gift tax on their worldwide assets,

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