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Brent Nelson
ACTEC Fellow and trust-and-estate lawyer from Tucson, Arizona, specializing in cross-border trust taxation and planning for foreign non-grantor trusts with U.S. beneficiaries.
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Oct 14, 2025
• 13min
Taxation of Foreign Non-Grantor Trusts
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Brent Nelson, an ACTEC Fellow and expert in cross-border trust taxation, dives deep into the complexities of foreign non-grantor trusts. He clarifies how classification hinges on trustee control and the differences between grantor and non-grantor rules. Brent discusses strategic planning for U.S. beneficiaries, including timing for residency changes and managing distributions to avoid penalties. He also explains crucial U.S. reporting obligations, ensuring listeners are well-equipped for successful cross-border estate planning.
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