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 ...

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