Grantor Trust (Australian)

[Laurence K.]

I have an Ohio LLC (single member-disregarded entity) that is 100% owned by a Wyoming LLC (single member - disregarded entity) that is 100% owned by an Australian Discretionary Trust.

I am of the understanding that the Australian Trust is considered a Grantor Trust by the USA and that any taxes due from my Ohio LLC are passed down the line, first to my Wyoming LLC, then to my Australian Trust, and then to the Grantor of the trust.

The Australian trust has as its trustee an Australian company (Corporate Trustee).

I am the sole director of the Corporate Trustee.

The beneficiaries of the trust are my my wife & I, our adult children, grandchildren & any as yet unborn heirs.

So my question is

WHO IS THE GRANTOR ?????

[Lance Lvovsky]

@Laurence K.

Who settled (funded) the trust? To be a US trust must meet both the control test and court test (jurisdiction). If foreign trust, you may have a 3520A filing requirement which needs to be filed with the IRS annually ($10,000 penalty if not filed). You should consult with a tax advisor who specializes in the area of trust taxation.