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Interest income earned by the trust is deductible if distributed to a foreign beneficiary but because the beneficiary is a nonresident alien, he will not be subject to U.S. income tax on the distribution. Therefore, the income is not subject to withholding tax (see Rev. Rul.
A revocable trust and living trust are separate terms that describe the same thing: a trust in which the terms can be changed at any time. An irrevocable trust describes a trust that cannot be modified after it is created without the beneficiaries' consent.
Trusts in Japan. Despite its civil law tradition, Japanese law allows the creation of trusts as an estate- planning device. Whether trusts created under for- eign laws have effect with regard to Japanese assets, however, is less clear. Japanese statutes don't directly address this issue.
Yes, once the trust grantor becomes incapacitated or dies, his revocable trust is now irrevocable, meaning that generally the terms of the trust cannot be changed or revoked going forward. This is also true of trusts established by the grantor with the intention that they be irrevocable from the start.
Trusts, including trusts established abroad, are recognised and permitted in Japan both for legal and tax purposes.