Just Off the Boat, Trust Fund in HandJust Off the Boat, Trust Fund in Hand
Many wealthy people today spend substantial amounts of time in various countries and many may eventually find themselves becoming tax residents of the United States. So U.S. trusts and estates practitioners shouldn't be surprised if a client presents them with this interesting question: How will the United States tax distributions of income accumulated before such beneficiary became a tax resident
Jose L. Nuñez, shareholder, and Andrea L. Mirabito, associate, Packman, Neuwahl & Rosenberg,
Many wealthy people today spend substantial amounts of time in various countries and many may eventually find themselves becoming tax residents of the United States. So U.S. trusts and estates practitioners shouldn't be surprised if a client presents them with this interesting question: How will the United States tax distributions of income accumulated before such beneficiary became a tax resident of the United States?
How will you answer?
Let's say your client, Ben Tex Aver, is a non-U.S. citizen from Bermuda, a country with which the United States has no comprehensive income tax treaty in effect.1 He recently obtained permanent lawful U.S. residen...
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