
Beyond Accounting Bitesize
Expatriate Tax Maze (Part 5): Foreign Trusts, Throwback Tax & Hidden Traps
Foreign trusts are where some of the most expensive surprises in cross-border tax live. A trust quietly settled overseas — sometimes years before anyone in the family imagined moving to the United States — can trigger deemed realization events , punitive throwback taxes , and reporting obligations that catch families completely off guard. In the final episode of Navigating the Expatriate Tax Maze, Peter Trieu of BDO walks through: What actually makes a trust "foreign" in the eyes of the IRS (the control test and the court test) The critical difference between foreign grantor trusts and foreign non-grantor trusts How distributions to US beneficiaries are taxed — and why the throwback tax regime is so punishing The 5-year rule that pulls pre-immigration trusts back into the US net The deemed-sale trap when a foreign grantor trust converts to a non-grantor trust Form 3520 and 3520-A reporting requirements every US beneficiary and grantor needs to know A fitting close to the series — and a reminder that with foreign trusts, planning ahead is everything. If anything in this series raised questions about your own situation or your employees', Dave Zydek and Peter Trieu welcome a direct conversation. Contact details and the full series are available at cawnetworkusa.com. Brought to you by CAW Network USA in partnership with BDO.

