Trust Change Beneficiary With Foreign
Description
How to fill out Amendment To Trust Agreement In Order To Change Beneficiaries?
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FAQ
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.
In addition to the withholding requirement, naming a beneficiary who resides in a foreign country may allow the foreign country to tax the property and accounts of the trust. In most cases, a foreign person is subject to US tax on its US source 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.
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.