Causing a trust settled under the law of a U.S. state to be classified as a foreign trust for U.S. federal income tax purposes is easy. It can be equally easy for a foreign trust classification to happen accidentally. While there are ways to cure this accident without U.S. tax consequences, it’s increasingly more common for a client’s facts to present a recipe for this situation to occur as the world grows smaller. Consider a green card holder, domiciled in the United States, desiring to
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