A non-resident alien (NRA) man wants to hold US assets (e.g. real estate, corporation stocks). He is not a US citizen, but his minor child is a US citizen who is also not a resident of US and lives with him. They are residents of Canada.

The man wants to setup a Trust structure and hold assets in Trust, so that upon his death the child can either take over the trust, or take over the assets directly. The man also plans to become a resident of US in the far future, together with his son.

What Trust structure should he setup now, before he buys any assets in US, in order for his child to take ownership of all the assets without paying any estate taxes?

In the following article various scenarios are described, but none matches the scenario that I described.


Please describe which type of trusts to create, and in which country, and how will they work together. If a corporation is necessary, please add that to the mix.

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