US tax treatment of foreign grantor trust during the year of the Grantor's death

This article, specifically, addresses the US tax treatment ofa foreign trust that changes from a foreign grantor trust toa foreign non-grantor trust when the grantor (settlor) diesduring the year and how the trust accounts for its distributednet income and undistributed net income in the year of death.¹     

Taxation of non-resident trusts in Canada and taxation of Canadian beneficiaries of non-resident trusts qualified as foreign investment entities

As a general rule, non-resident trusts are not subject to taxin Canada and distributions from Canadian non-resident trustsare not subject to tax in the hands of the Canadian beneficiaries.However, there are exceptions. The purpose of this article isto focus on the new conditions under which a non-resident trustcould be subject to tax in Canada or treated as a foreign investmententity for tax purposes which triggers a Canadian tax liabilityfor the beneficiary.