Elena Marty-Nelson (Nova) has posted Taxing Offshore Asset Protection Trusts: Icing on the Cake?, 15 Va. Tax Rev. 399 (1996), on SSRN.  Here is the abstract:

Income and transfer tax considerations that favor overseas asset protection trusts (OAPTs) compared to domestic asset protection trusts are contrary to sound tax policy. Tax laws should not operate to encourage taxpayers to move assets overseas to be beyond the reach of US creditors because doing so may undermine the tort system. To the extent asset protection is allowed, OAPTs should not be governed by rules more lenient than those faced by domestic trusts. Estate tax laws regarding creditor access should be interpreted to apply equally to domestic and foreign trusts.