London: +44 (0)20 7236 2601
St Albans: +44 (0)1727 869141
Rickmansworth: +44 (0) 1923 771010
Milton Keynes: +44 (0)1908 605552

Bad news for US beneficiaries of foreign trusts

Last month the American version of HM Revenue and Customs, the IRS published a radical “technical advice memorandum” (TAM) which set out its view that US beneficiaries of offshore (i.e. non US) trust / holding company are taxable on a corporate reorganisation within the structure under the Passive Foreign Investment Company (PFIC) rules.

 

 

Date: 13th September, 2007
Author: Lisa Spearman

SHARE THIS

Articles from this Author

Contact a Private Client Partner

Tweet

“Good luck to everyone who has also made it as a finalist, I look forward to awards evening later on in the year”-L… twitter.com/i/web/status/8…

Michael Lapham shortlisted in the Money Management Financial Planner Awards 2017 bit.ly/2fL8VXBtwitter.com/i/web/status/8…

Follow

LinkedIn

For the latest Mercer & Hole news, visit our LinkedIn page mercer-&-hole

Click here to follow us on LinkedIn