Question: Uncle Sam, a U . S . citizen, dies with a substantial U . S . gross estate which, after taking into account all deductions,

Uncle Sam, a U.S. citizen, dies with a substantial U.S. gross estate which, after taking into account all deductions, exemptions, and credits other than the marital deduction, would otherwise result in a U.S. estate tax. To avoid that tax, Uncle Sam leaves the remaining assets in a Qualified Domestic Trust for the benefit of his non-U.S. citizen spouse, Fanny Foreign. If Fanny were to receive from the Qualified Domestic Trust a non-hardship distribution in excess of income, the Trustee of the Qualified Domestic Trust would have to file a:

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