EXAMPLES OF ABUSIVE TRUST ARRANGEMENTS

Part Five

The Final Trust

In some multi-trust arrangements, the owner of one or more abusive trusts establishes a trust (known as the "final trust") that holds trust units of his other trusts and is the final distributer of their income. A final trust often is formed offshore in a foreign country that imposes little or no tax on the trust. In some arrangements, more than one foreign trust is used with the cash being channeled from one trust to another until the cash is finally distributed to the U.S. owner, allegedly tax free.

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