It's essential that practitioners know not only the fundamentals of U.S. federal income taxation of foreign non-grantor trusts and their beneficiaries, but also the ways to plan around the “throwback tax” that's imposed on distributions of accumulated income to the U.S. beneficiaries of these trusts. Of course, if you can't avoid the throwback tax, you're going to have to know how to calculate it. And advisors must be aware of the U.S. tax reporting requirements related to foreign non-grantor
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