The December 2017/January 2018 issue of the STEP Journal contains part two of an article by Danilo Santucci, Senior US Tax Counsel and Wealth Planner, discussing 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 TWO, focuses on domestication, variable life insurance, and variable annuities. Have a look at the part two article here (STEP Journal: Volume 25/Issue 10).
PART ONE, published in the November 2017 issue focused on distribution techniques and the use of underlying entities. View part one here (STEP Journal: Volume 25/Issue 9).