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A Foreign Grantor Trust is a trust in which either: (a) the Grantor reserves the right to revoke the trust alone or with the consent of a related party, or (b) the Grantor (and spouse, if any) is the sole trust beneficiary during the Grantor's lifetime.
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.
The US citizen can leave property to a trust, rather than giving it outright to the non-US citizen. The only beneficiary in the trust is the non-US citizen spouse until he/she dies. The trust will provide income from the trust without having to pay the estate tax.
About the Foreign Grantor Trust Owner StatementThis 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.
US grantor (US citizen or resident): A trust is considered a grantor trust when the grantor retains a certain degree of dominion and control over the assets of the trust and is thus treated as the owner of the trust for US federal income tax purposes.