High Net Worth Family Restructures Foreign Trusts

High Net Worth Family

Representation of a high net worth family whose stock holdings in a major consumer products company total close to $1 billion, the majority held in foreign trusts. The trusts were restructured to make potential distributions more tax efficient. The trust restructuring involved permitting distributions to the U.S. in the form of qualified dividends, taxable at a 20 percent rate versus the higher ordinary income tax rate. The impact of the throwback rules that apply to accumulated income which is distributed from a foreign trust to a U.S. beneficiary was also minimized.

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Richard M. Goldstein

Richard M. Goldstein

Partner, Tax and Estate Planning Group Chair
Mildred Gomez

Mildred Gomez

Partner
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