During the late 1990s, U.S. tax law became increasingly hostile to offshore trusts1 that benefit U.S. taxpayers. Tax compliance and planning became much more difficult for non-grantor trusts — and new rules put more offshore trusts in the non-grantor category if they were established by a non-U.S. grantor. As a result, many trusts established by multi-national families in trust-friendly tax havens for the benefit of their U.S. family members have since migrated to the United States
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