With increasing global mobility of high-net-worth individuals and families, it’s becoming more common for a U.S. fiduciary to be the trustee of a trust that’s governed by the laws of a U.S. state and has non-U.S. beneficiaries. Consider a retired, non-U.S. married couple that immigrates to the United States and has children who remain non-U.S. individuals. If that couple sets up a typical core estate plan with a trust and U.S. trustee, on their deaths, there would likely be one or more
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