Foreign Trust Funding Peril

Foreign Trust Funding Peril

Advise NRA grantors to steer clear of IRC Section 2104(b)


Non-resident aliens (NRAs)1 seeking to avoid U.S. estate tax on foreign trusts may find Internal Revenue Code Section 2104(b)2 to be particularly confounding and nettlesome. Under IRC Section 2104(b), some transfers of property, by trust or otherwise, made within three years of death or over which an NRA decedent retained certain types of intere

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