Category Archives: Foreign Taxation

Taxation of Foreign Nongrantor Trusts: Throwback Rule

Posted on August 4, 2014 by David L. Silverman, J.D., LL.M. (Taxation)

I. Introduction  The throwback rule is intended to prevent a foreign trust from accumulating income, thereby delaying the reporting of that income by U.S. beneficiaries until the time when the income is eventually distributed. The throwback rules defeat this income … Continue reading →

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