Most issues of the APN dealing with offshore trusts have focused on the use of such trusts for asset protection. Another, very important, use of a certain type of offshore trust is to effect an estate tax savings. This is accomplished by “freezing” the value of trust assets vis-a-vis the settlor’s estate at current values.
Combining a carefully selected offshore annuity with a properly designed offshore trust can provide a powerful asset protection planning option.
On the tax side of rendering estate planning services, the estate planner is faced with Federal income, gift, estate, and generation-skipping tax issues. All of these issues (and more) must be addressed in the context of an irrevocable life insurance trust (“ILIT”) established in a foreign jurisdiction.