Technical article
Reading the Payout Table: Four Heirs, Four Countries, One Trust
The table shows two numbers for each heir, a low and a high.
Picture a US settlor with a trust of US$20 million, run from the Cayman Islands. It pays out 3% a year, which is US$600,000, shared equally among four heirs: one in Mexico, one in Portugal, one in Brazil and one in Thailand. Each receives a share of US$150,000 before tax. The amounts and the yield are examples. How do I read the table that shows what each heir receives?
The table shows two numbers for each heir, a low and a high. They are not a forecast and not a guess. They are two rules applied to the same payment.
How the range is built
The payment first meets tax at its source. In this example the United States withholds up to 30% of US-source income paid to an heir who is not a US person. The tool assumes half of the trust's income is US-source, so the withholding runs from zero to US$22,500 on each US$150,000.
Then the heir's own country applies its rate. The two ends of the range treat that second step differently.
- The low end gives full credit for the tax already paid. The heir's country charges its lowest rate on the whole payment, and the total tax is the larger of that and what was taken at source.
- The high end gives no credit. The source tax is taken, and the heir's top rate is charged on what is left.
Real life usually falls between. Treaties, credits and the heir's other income decide where. The table does not include treaty rates, state and city taxes, church tax or wealth taxes unless a row says so. It assumes the trust pays out all its income each year, and growth is not modelled.
The four heirs
| Heir lives in | Rate range used | Tax on US$150,000, low to high | Heir keeps, low to high | Basis |
|---|---|---|---|---|
| Mexico | 10% to 35% | US$15,000 to US$67,100 | US$82,900 to US$135,000 | Trust rule found (B) |
| Portugal | 28% to 35% | US$42,000 to US$67,100 | US$82,900 to US$108,000 | Trust rule found (C) |
| Brazil | 15% flat | US$22,500 to US$41,600 | US$108,400 to US$127,500 | Trust rule found (B) |
| Thailand | 0% to 35% | US$0 to US$67,100 | US$82,900 to US$150,000 | Top rate only (B) |
Figures are rounded to the nearest hundred where they are not whole.
What "top rate only" means
For Thailand the sources gave the top income-tax rate, 35%, but not how a payment from a foreign trust is treated. When that happens the low end is zero and the high end is the top rate. That is why the Thai range is the widest: it has the least rule behind it. Thailand taxes foreign income brought into the country from 2024 (sources differ on income earned before 2024). That detail is in the notes, and the range does not use it.
Brazil's range is narrow because a 15% flat rate on trust income was found. Sources differ on who pays it, the trust owner until a payment or the heir each year (tiers B and U). The table uses 15% for both ends. Mexico treats a foreign trust as transparent and counts the income yearly at 10% to 35%. Portugal's 28% is a flat rate on investment income, and 35% applies to a trust under a favourable regime (tier C).
What "not found" means
A cell that says not found means the sources reached did not say. The table counts it as zero and lists it above the results, so the total reads low by that amount. In this example the yearly government fee at Cayman reads not found for that reason.
Why a wide range is still useful
The first example in the tool has a US$20 million trust, three heirs and 60 years. The yearly payout after tax runs from US$331,500 to US$525,600 of US$600,000. All the taxes in the tool over 60 years add up to between about US$4.5 million and about US$20.1 million. That is a wide gap, and it tells us where to look: at the heirs' countries, and at the credit they give.
You might say a range this wide is no use for planning. A range tells us which questions carry the money. For Thailand, it is how a trust payment is treated. For Mexico and Portugal, it is how much credit is given for tax already paid. You could ask each heir what their country does, and then replace the range with one number.
Who it touches
Each heir, whose number is theirs alone. The trustee, who withholds at source. The settlor, who sees what finally arrives. An heir who moves from one country to another changes the row.
If you have tried to explain a table like this to your family, which part needed the most words? Share it here. Another family may be about to open the same table.
Figures are estimates for planning, based on public data. Date read: October 2026.
Sources
- Internal Revenue Code ss.871 and 1441 and IRS Publication 515 (A)
- Mexican tax guide, 2026 (B)
- Portugal investment income guide (C)
- Brazil Law 14.754 and EY guide (B)
- Thailand tax guide (B)
- Cayman tax guide (B)
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