In the first part of this article,¹ we discussed the income tax saving opportunities offered by non-grantor trusts. We will now discuss some disadvantages of non-giving trusts in both domestic and international contexts. In cross-border situations, the challenge is usually to manage complexity and avoid pitfalls for the unwary. In the domestic context, often the key is to weigh the short-term income tax benefits that a non-grantor trust can bring against the long-term estate tax savings that