Post-Mortem Considerations with Foreign Grantor Trusts After H.R. 1, Tax Cuts and Jobs Acts.

The article focuses on the U.S. Tax Cuts and Jobs Acts with the foreign grantor (FC) to be liquidated for U.S. tax purposes after the death of the non-U.S. person grantor. It mentions post-mortem planning and U.S. tax-planning structures for families with a non- U.S. person parent and structure avoids the imposition of the U.S. estate tax. It also mentions U.S. income tax liability to the non-U.S. person grantor for the sale of the foreign assets.