US tax treatment of foreign grantor trust during the year of the Grantor's death |
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| Authors: | Bruce Charles M; Bonnard Yves |
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| Institution: | * Charles M. Bruce is the partner in charge of the London office of Moore & Bruce, LLP. His practice is principally comprised of international tax planning and compliance matters. At various times he was Adjunct Professor of Law, Graduate Law Program, Georgetown University Law Center. He has authored, edited or presented a number of books, articles and presentations including: New U.S. Withholding Tax Rules: A Practical Guide (Transnational Publishers, Inc. & Richmond Law & Tax Ltd., 2002) and United States Taxation of Foreign Trusts (Kluwer Law International, 2000).
** Yves Bonnard is a founding partner of Bonnard Lawson, a Swiss law firm with offices in Geneva, Lausanne and Shangai. He is the author of several publications and gave numerous presentations in the area of international wealth planning, trust, life insurance, relocation in Switzerland and management of art collections. |
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| Abstract: | 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 |
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