Tax Notes Article by Jonathan Zhu, "Cross-Border Tax Issues Involving Single-Owner Grantor Trusts"

Tax Notes has published an article by Jonathan Zhu, partner with Wilson Sonsini Goodrich & Rosati PC, Palo Alto, CA. The article argues that, for federal income tax purposes, single-owner grantor trusts are not identical to disregarded entities. In addition, Zhu proposes an alternative to the hornbook view of the interest source rule involving a trust debtor. 

See Jonathan Zhu, "Cross-Border Tax Issues Involving Single-Owner- Grantor Trusts," 122 Tax Notes 1247 (March 9, 2009)

Posted by Min Young Choi, Associate Editor, Wealth Strategies Journal.