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Foreign Trust Tax Review

Trust, Estate and Family - 08 Feb 2017

The Foreign Trust Tax Review is a service aimed at assisting non-US Trustees with understanding potential US tax considerations for non-US trusts and connected parties.

This is a three step programme, designed to identify any potential US tax issues that are connected to a foreign trust and to provide guidance as to planning opportunities and options available for rectifying any prior issues.

STEP 1 – Information Gathering

A focused and concise process designed to understand the background history relating to the trust, and connected parties (settlor/beneficiaries), and straight forward collation of required information.

This allows us to understand the trust situation and provide clear fee quotes based upon the representations made.

STEP 2 – Information Review

Detailed analysis of information gathered to include: 

  • Identification of US Connected Persons
  • Determination of US tax status of the foreign trust
  • Review of tax position relating to underlying structures

STEP 3 – Advisory Memo

Provide clear guidance relating to planning opportunities available and advised next steps.
The Foreign Trust Review provides clear and practical guidance in respect of many US connected issues, including recognition of valuable planning opportunities as well as a review of prior year activities. Some examples of where we can provide benefit includes:

  • Planning for settlor/beneficiary looking to move to the US
  • Identification of US connected persons and related compliance requirements at all levels
  • Rectification of previous non-compliance position
  • Succession planning

To discuss these three steps in more detail, please contact your usual Frank Hirth adviser or connect with us by emailTwitter or LinkedIn.

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Iain Younger

Iain Younger


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Office: London