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Trusts can have multiple beneficiaries, including the trustee. Naming a non-US citizen as a beneficiary of a Trust could have consequences for inheritance or income-tax. For one, selecting a foreign citizen as a beneficiary can expose the Trust to increased tax liability.
A statement that the trust will permit either the IRS or the U.S. beneficiary to inspect and copy the trust's permanent books of account, records, and such other documents that are necessary to establish the appropriate treatment of any distribution or deemed distribution for U.S. tax purposes.
Foreign nongrantor trusts All trusts that are not grantor trusts are considered nongrantor trusts for US purposes. Foreign nongrantor trusts are not generally subject to US tax, unless the trust earns US source or effectively connected income.
This form is required by the Trustee of the foreign trust, to provide the IRS with information as to which US Beneficiary received a foreign trust distribution.