The November 2017 issue of the STEP Journal contains part one of an article by Danilo Santucci, Senior US Tax Counsel and Wealth Planner  that discusses select strategies to address the complex rules that come into play when a foreign trust has US beneficiaries, commonly referred to as the throwback rules. The article addresses US income and transfer tax issues, as well as administrative cost and other practical considerations. Part one focuses on distribution techniques and the use of underlying entities.
Click here to view the article as originally published in the STEP Journal (STEP Journal: Volume 25/Issue 9).