Exit Tax Trust

The Exit Tax Trust is a recent development in the world of international tax planning. Put plainly, it applies the mechanics of Delaware Incomplete Non-Grantor (DING) Trusts, Beneficiary Defective Inheritor Trusts (BDITs), or even Net Income Makeup Charitable UniTrusts (NIM-CRUTs), depending on the situation and your expatriation plans, coupled with the exception for interests in non-grantor trusts under Section Sections 877A(c)(3) and the special treatment of distributions therefrom under Section 877A(f).

Long story made short: the Exit Tax only applies to the uninformed. It matters not what your net worth is. Our Exit Tax Trust would permit even a billionaire to expatriate from the United States entirely tax-free. Contact us today to schedule a free consultation to learn more. We take no offense to request that we include your current tax attorney or CPA on the line. We understand there is much at stake, and we want all of our clients to feel comfortable and confident that our planning solutions are 100% in compliance with existing law. We only engage in the kind of planning you could openly disclose to the IRS without concern.

“In America, there are two tax systems: one for the informed and one for the uninformed. Both are legal.” The Honorable Learned Hand, United States Court of Appeals (1872-1961)


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