Skip navigation

When Foreign Trusts Own Foreign Companies

Tax professionals increasingly are providing advice for clients who are U.S. beneficiaries of foreign trusts. These clients may be subject to tax on income earned by, or from, controlled foreign corporations (CFCs) and passive foreign investment companies (PFICs) whose shares are held in trust. Both of these regimes, also known as anti-deferral regimes, reduce the deferral (or the benefits of deferral)
Resources

Tax professionals increasingly are providing advice for clients who are U.S. beneficiaries of foreign trusts. These clients may be subject to tax on income earned by, or from, controlled foreign corporations (CFCs) and passive foreign investment companies (PFICs) whose shares are held in trust. Both of these regimes, also known as “anti-deferral regimes,” reduce the deferral (or the benefits of deferral) of U.S. income tax that generally exists for U.S. shareholders of domestic corporations.

All access premium subscription

Please Log in if you are currently a Trusts & Estates subscriber.


If you are interested in becoming a subscriber with unlimited article access, please select Subscription Options below.


Questions about your account or how to access content?


Contact: [email protected]

TAGS: Archive
Hide comments

Comments

  • Allowed HTML tags: <em> <strong> <blockquote> <br> <p>

Plain text

  • No HTML tags allowed.
  • Web page addresses and e-mail addresses turn into links automatically.
  • Lines and paragraphs break automatically.
Publish