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accumulation distribution amount annuity apply asset protection trust attorney bank Bermuda Cayman Islands charitable claims client Code Cook Islands court creditors death decedent decedent's determined discretionary trust domestic effectively connected established estate planning estate tax exempt expatriation Federal filed foreign corporation foreign nongrantor trust foreign person foreign trust FPHC fraudulent conveyance funds gift tax grant grantor trust gross income imposed individual interest International investment issued jurisdiction liability loan marital deduction noncitizen spouse nonresident alien obligation OECD offshore trust organization partnership payment personal holding company PFIC private foundation provides QDOT tax qualified settlor shareholder situs spendthrift trust statute surviving spouse tax havens tax purposes Tax Treaty taxable taxpayer transferor Treas Treasury Regulation treated trust assets trust instrument U.S. beneficiary U.S. citizen U.S. income tax U.S. person U.S. real U.S. source U.S. tax United