Why would you set up a foreign grantor trust when there are no US assets, only foreign assets?
I understand if there were US sited assets as the foreign person would need to file a gift tax return and pay gift taxes if a foreign grantor trust is not used.
Presumably there is no estate tax as the decedent would be a foreign peson.
Any help in understanding is greatly appreciated!
Tax Professional Answers
The father's intent may have more to do with his own tax and succession issues than with US tax issues per se. What may be required is for you to liaise closely with the father's advisers to ensure what they have in mind causes no unwelcome US income, gift or estate tax issues for your client.
Depending on the jurisdiction/s of residence of the father and locus of the assets, the father's advisers may have significant hurdles to clear.
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