Does an Offshore Trust Preserve the Step-Up in Basis? Rev. Rul. 2023-2 says completed gifts to a grantor trust get no §1014 step-up. Most offshore trusts are completed gifts. What that costs, and the design question that decides it.
Automatic Migration Provisions Under Treas. Reg. §301.7701-7. A trust that migrates offshore automatically when a creditor sues is foreign from the day it was created. The regulation says so, with an example. What a properly drafted instrument does instead.
I Just Got Sued — Is It Too Late to Protect My Assets? For the claim already filed, largely yes — moving assets now is a voidable transfer. For claims that don't exist yet, no. What still works, and what makes it worse.