That would have been paid if DNI had been distributed and taxed to the beneficiary in the years in which it was earned. Regular income tax is imposed on the distribution in the U.S. beneficiary 's hands, plus an interest charge on the tax. The interest charge is compounded over the length of time that the..The U.S. beneficiary should receive a Foreign Grantor Trust Beneficiary Statement Form 3520-A, or a Foreign Non Grantor Trust Beneficiary Statement which includes information about the taxability of distributions they have received and foreign trust income they must report..As mentioned, if Form 3520-A is not filed, penalties are imposed on the U.S. owner. Obligations of the Trustee: The trustee should provide a Foreign Grantor Trust Beneficiary Statement to the U.S. recipient of any distribution, to report the amount of the distribution..Furthermore, such throwback distributions will be taxed at ordinary income tax rates. Generally, the Trustee should furnish to the U.S. beneficiary a "Foreign Nongrantor Trust Beneficiary Statement", which will be attached to the Form 3520..
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