Trust Structures with US Connections

There are many benefits of using a trust, including asset protection and management, generational planning and for income tax and estate tax purposes.


Trusts can play an integral role in asset management and protection, generational planning, as well as income and estate tax planning. However, the transfer of assets to a spouse, children and other beneficiaries will almost always have tax implications, especially for US Persons. 

The US tax treatment of non-US trusts involving US-connected persons, e.g. US settlors, US beneficiaries, or certain types of US income, is complex from both a reporting and US tax perspective. Adding to this complexity is the fact that trust structures tend to invest in or through non-US corporations, which can lead to additional informational reporting. Furthermore, the income/gains realized through these companies could potentially be taxed directly to the US settlor/beneficiaries, even though such amounts may not necessarily have been distributed to them. This becomes particularly complex with multinational families.  

Our dedicated US Trust division offers the most up-to-date advice to ensure our clients plan, navigate and report on these complexities.

We work with many different types of trusts including:

  • Complex trust structures
  • Foreign and domestic trusts
  • Grantor and Non-Grantor trusts

Our Advisory Services

  • Practical and clear advice around the trust structure ensuring US tax efficiency while maintaining the integrity of the trust
  • Advice on the US characteristics of a non-US trust and detail the compliance requirements for the US-connected person
  • The necessary US tax calculations (income, basis, financial reporting)
  • Advice in relation to different US States where a US trust is established as part of the planning
  • Documented support for tax positions taken
  • Assistance to the trustee with its obligations under FACTA, QI and Common Reporting Standard regimes

Our Compliance Services

We can identify and prepare all the US reporting requirements needed by the Trust, the Settlors and Beneficiaries.

Failure to file the returns and reports in a timely manner, or incorrectly, can result in substantial penalties.

High-quality, compliant filing and planning decisions

For over 35 years we have provided US tax guidance, compliance, and planning. Our highly skilled and expert US tax accountants and attorneys offer our customers tailored and reliable tax assistance. To discuss how we may support you, please Contact us.