Using The Foreign Nongrantor Trust In Offshore Testamentary Estate Planning
(J. Richard Duke and Selwyn Gerber)

A foreign nongrantor trust can be structured to pay no capital gains tax on gains in the U.S., or no income tax on investment income and interest in the U.S., and to provide for tax-free accumulation of wealth. A tax-neutral foreign grantor trust that is used as an asset protection vehicle and to provide access to attractive international investing opportunities becomes a foreign nongrantor trust on the death of the settlor. By navigating the complex rules and reporting requirements regarding distributions from foreign nongrantor trusts, the tax efficient multi-generational retention and growth of wealth may be available.

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Exhibit A - Foreign Nongrantor Trust(20KB)
Exhibit B - Foreign Nongrantor Trust(20KB)
Exhibit C - Foreign Nongrantor Trust(20KB)