Overview
Michael Rosen-Prinz will present “Compliance and Planning Conundrums Involving Foreign Trusts and PFICs” at the STEP Los Angeles Advanced Conference.
Topics will include:
- Treatment of accumulation distribution to US residents
- Interaction of PFIC inclusions and trust distributions to US residents
- Avoiding retained interests of foreign settlors under IRC §2104(b)
- Maintaining grantor trust status beyond date of death of settlor
- Characterizing and reporting of civil law foundations and other foreign trust-like structures
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