▲ 1 r/legal

Illinois: Foreign Non Grantor Trust

A foreign settlor settled Non-US assets in a Foreign trust with non US Beneficiaries at the time of settlement. Trust is Irrevocable and Discretionary. Trustees are independent. Settlor remains one of the beneficiaries among other family members, namely parents and sisters.

By taking above facts as is,

Q1) is the above trust fund classified as FNGT, irrespective of settlor being Discretionary benefciary?

Q2) does the classification change if settlor immigrates to the US, if yes, what's the new classification?

- student from Chicago

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u/Radiant-Cloud92 — 12 hours ago

Foreign Grantor Trust

What is the estate taxation status for some who say puts US situs assets like a Wyoming LLC into a Wyoming Irrevocable Trust, and appointing a Domestic trustee.

I want to know estate tax consequences in below two scenarios:

  1. grantor is. Foreigner

  2. foreign grantor becomes a US resident after settlement in foreseeable future.

-United Kingdom

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u/Radiant-Cloud92 — 1 day ago

How's the tech industry in Singapore?

It's favorable tax status has made registration for more than 8000+ tech Indian startups. But is singapore more than a favorable registration hub? How good is the tech talent here, how's the startup ecosystem, meaning are there sizeable incubators, VCs and accelerators?

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u/Radiant-Cloud92 — 1 day ago

What are the first references of Vedas being 'Aprusheya', and Dharma being 'Sanatan'?

I want to know etymology of these words. Where can we trace them back to its origins? The Dharmic Literature is vast. Can anybody who's studied them, speak about this?

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u/Radiant-Cloud92 — 2 days ago

Is there a possibility that China would maintain 'one country two systems' policy indefinitely?

What is the hypothesis of economists and bankers for its future? Read in a report that currently HKD's monetary base being US dollar reserves are 114% of the Hong Kongs economy, so depegging HKD to yuan doesn't seem plausible in near future atleast. But even if they did, the 70% foreign investment of China that flows through hong kong with CNH seems at risk too. The courts also have been running on English law for long time now.

Perhaps I could be wrong, but what do y'all feel?

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u/Radiant-Cloud92 — 4 days ago
▲ 0 r/expats

Hong Kong vs Singapore

As a finance job worker, it boils down to whether you want to work in M&A, Investment Banking services for Chinese based companies, while based in Hong Kong, or wanna work in Wealth Management or Private Equity, focusing on regional asian economies while based in Singapore.

But other than the job opportunities, what are good reasons to live in either of them. I would predict that for financial prosperity, it's a bet either ways. But can't decide about factors for lifestyle.

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u/Radiant-Cloud92 — 6 days ago
▲ 3 r/tax

Gift and Estate taxes on Trust

Foreign resident willing to immigrate to the US. Have already transferred wealth in an irrevocable trust fund, with no US situs assets. Trust is settlor interested. What are the implications regarding gift and Estate taxes upon immigration?

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u/Radiant-Cloud92 — 9 days ago

Have any US citizen in the community tried PPLI structure for tax saving?

Want to know how much is the minimum and maximum limit while transferring wealth into these things, would also appreciste knowledge about fees and performance involved🙏

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u/Radiant-Cloud92 — 9 days ago

Regarding Tax Managed Investing

Has anyone tried Direct Indexing through a Tax-Managed SMA (Separately Managed Account)? I'm interested in knowing what portfolio performance has looked like after fees, taxes, and withdrawals for income. Also curious whether people have managed to produce tax alpha over long periods of time because I'd assume cost basis of securities shall reduce hence diminishing opportunities. Correct me if I'm wrong.

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u/Radiant-Cloud92 — 10 days ago

Regarding Tax Managed Investing

Has anyone tried Direct Indexing through Tax Managed SMA (Separately Managed Account)?

Wanted to know what does portfolio performance look like, net of fees, and withdrawals for income.

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u/Radiant-Cloud92 — 10 days ago
▲ 13 r/Malibu

What is a day in life of wealthy beachside Malibu residents?

My perception is influenced by Charlie Harper of TAAHM, which fascinated me 😂

But offcourse reel and real life are different. Hence wanted to know what's it actually like living there and commuting to LA. Wonder how do these A list actors and Realtors who have primary residence in Malibu colony, live there. it's such a long drive from LA, both for work and leisure.

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u/Radiant-Cloud92 — 11 days ago

What are FEMA rules and regulations for setting an Foreign Trust Fund

Only LRS and ODI material available. But setting an offshore trust fund material not available. What's the stance? Please guide, want to setup Irrevocable Trust Fund with cash below 250K dollar limit, as per LRS.

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u/Radiant-Cloud92 — 12 days ago
▲ 3 r/uklaw+2 crossposts

Regarding Non Resident Settlor interested Trust Law

The Irrevocable Discretionary Trust Fund, which is non resident, is Settlor interested, meaning settlor being the beneficiary of the trust as well.

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Under new statutory law, the abolished NONDOM regime and Protected Foreign Income Source (PFIS) regime, that protected foreign income of the trust now taxes settlor on 'Arising Basis', as per HMRC guidance. But the guidance maintains the fact that foreign trustees don't pay uk taxes on foreign income and gains.

​

Since the non resident trust is discretionary, which gives the right to the trustee to either distribute or accumulate earnings at their sole discretion, hence giving mere hope, but not the right to beneficiary. My question is, how is the settlor supposed to pay the taxes if the trustees decline to distribute the earnings? Doesn't this trap settlor with dry tax?

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u/Radiant-Cloud92 — 20 days ago

What is the legal scope for indians settling Offshore Trust Fund?

Say an Indian resident and citizen wants to create an offshore trust fund in Mauritius for wealth planning, what is the legal scope of it?

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Can he or can he not do it? And if yes, How?

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u/Radiant-Cloud92 — 21 days ago
▲ 1 r/expats

British expat Taxes upon returning to UK

Under Temporary Non Residence rules of UK, is other income like dividends and trust fund distribution recieved during non residency, in resident country (eg. uae), taxed back in UK as returning resident?

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Is there a scope of exemption under DTAA in UK-UAE treaty?

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u/Radiant-Cloud92 — 21 days ago

Naam Jap on Counter Finger Ring

I put counter ring on my finger to do jap. But often times, I have to consciously tell myself to do jap and then keep pressing that button. Without conscious effort I just forget to do jap. It's not habitual yet. There are days where I put ring but don't do much at all, very little jap happens, that too when I become conscious that I have to do it, which makes me guilty.

How do I make a habit of this, and make jap habitual that it happens instinctly, without conscious thinking and effort to do it?

Basically sochna nahi pade, bas jap chalte rahe, uss stage pe kaise pohonche?

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u/Radiant-Cloud92 — 28 days ago
▲ 28 r/keto

KETO dish for same meal every day

I'm seeking Keto dishes which I can stick to for daily eating. Boredom isn't an issue for me. My only requirement is that meal should cover most of micronutrients, especially Vitamin B and C, given it comes from natural sources.

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u/Radiant-Cloud92 — 1 month ago

Incorporating US LLC for small tech startup

Have been reading online that solo tech founders or small teams are registering LLCs in Wyoming due to low cost and privacy. Wanted to know details for anyone who's done that here. Could you please share??

What's the taxation status? I heard that there is zero US corporate tax for foreign companies, and since there are no POEM rules under 50 crore revenue, it doesn't come under indian corporate tax as well. So what is the tax status of such entities. Pardon my ignorance and lack of knowledge, I'm only a curious beginner.

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u/Radiant-Cloud92 — 1 month ago

Filings for Foreign Asset Disclosure.

I'm Ordinarily Resident Indian, having No foreign source income, and India income less than 2 lakhs. I have ownership in a foreign company. Am I required to file it's disclosure?

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u/Radiant-Cloud92 — 1 month ago
▲ 24 r/keto

On keto diet, What are the drivers of high cholesterol?

I have noticed that on keto diet, LDL cholestrol can increase significantly above borderline levels. But I wonder what's the reason for this increase. Is it the consumption of Saturated Fats like Butter and Tallow? Or lack/ absence of carbs itself a driver for High LDL levels?

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u/Radiant-Cloud92 — 1 month ago