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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


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