If you’ve established that the legal arrangement is a foreign trust for US tax purposes, you should also evaluate the extent to which a US person retains decision-making authority over the foreign trust.
A US person’s authority over a foreign trust can significantly alter how the trust should be treated. For example, the level of decision-making authority a US person has over the trust will factor into whether the income of the trust should be taxed currently to US beneficiaries or when distributed to the US beneficiaries.
If you’re working with a US tax advisor, they may want to discuss the trust’s administration with the trustee to evaluate the level of decision-making authority US persons retain over the trust’s administration.