Question: 55. IF THE FPS HAD SET UP A FOREIGN NON-GRANTOR TRUST FOR THE BENEFIT OF SON 1 AND SON 2 SEVERAL YEARS AGO, WHAT ARE

55. IF THE FPS HAD SET UP A FOREIGN NON-GRANTOR TRUST FOR THE BENEFIT OF SON 1 AND SON 2 SEVERAL YEARS AGO, WHAT ARE THE POSSIBLE TAX IMPLICATIONS WITH RESPECT TO INCOME IN THE TRUST THAT HAS NEVER BEEN DISTRIBUTED OVER THE PAST SEVERAL YEARS AS SUCH INCOME DISTRIBUTION RELATES TO U.S. BENEFICIARIES

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