Over the years, planners have found several techniques useful in helping non-U.S. families pass wealth to the next generation: offshore personal investment companies (PICs), settlor-directed revocable trusts, controlled foundations, irrevocable trusts, independent foundations and specialized life insurance policies. These techniques are simple, and can be rather tax-efficient.1 But non-U.S. families with U.S. beneficiaries face special challenges. A host of U.S. tax rules combine to ...

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