Canadian estate, U.S. & Canadian benefiaries

[towerpants]

Repatriating to Canada soon as non covered expats. Question for estate planning as at least one of our children will be staying in the U.S. with a green card. The other may return to Canada but may not. Should we die we intend to transfer the bulk of our estate to a Canadian discretionary trust. Our understanding is it will be classified (in the eyes of the IRS) as a foreign non grantor trust and, as such, care needs to be taken on distributions to U.S. beneficiaries. All current income needs to be paid out of the trust & is taxable in the hands of the U.S. beneficiary BUT any distribution over & above the current income is a distribution of corpus and is not taxable. True? Due to children's ages (and depending on when we died) there might be a significant accumulation of income in the trust. If this accumulation was subsequently paid out to the U.S. beneficiary apparently there can be very negative US tax consequences (trust accumulation throw back rules).

Sorry for the long lead in here but here's the question. If one of the beneficiaries was a Canadian resident & citizen and one beneficiary was resident in the U.S., can the trust deem a distribution to the Canadian beneficiary as "accumulated income" and deem a distribution to the U.S. beneficiary as corpus? (thereby avoiding U.S. tax)

[towerpants]

Appreciate Nelson's contribution to this forum. Can Nelson respond if the question I've asked is too complex or too involved to be addressed in this forum? Appreciate any input on this. Thanks