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Managing Domesticated Former Foreign Trusts

Strategies to mitigate accumulation distributions of UNI.

For several decades, there have been strong U.S. tax reasons to keep a foreign trust offshore so that there’s reduced tax friction on the current earnings of the trust, thereby enhancing overall family wealth outside the U.S. tax net. Unfortunately, both U.S. practitioners and beneficiaries tend to underestimate the magnitude of compounded tax savings available offshore, leading them to erroneously assume that once accumulated offshore, tax-efficient access to wealth becomes unattainable.

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