Patel's death in order to avoid application of the onerous U. Controlled Foreign Corporation and Passive Foreign Investment Company rules to John. The advisor may recommend that the PIC be liquidated within 30 days of Mr.
situs intangible personal property, John's inheritance would be reduced by U. estate tax as the rules for transfers upon death are different than those made during life. The allocation of taxable income is achieved by permitting the trust a deduction for distributions of current income to beneficiaries of the trust. beneficiaries will be subject to tax and reporting. As part of sweeping anti-money laundering, anti-terrorism and tax collection efforts, oversight and scrutiny of foreign assets is growing exponentially on both a national and global basis. The income of the trust is taxed either to the trust, the beneficiaries, or partly to each. Forced heirship laws are not recognized by many offshore jurisdictions, such as the Cayman Islands, and attacks brought by heirs in the courts of these jurisdictions will likely fail. Besides avoiding the problems of mortality, a corporate trustee can provide the objectivity, experience and empathy that are keys to a successful partnership with the family over future generations. While family involvement may be appropriate, there are many advantages to having a corporate trustee or co-trustee of long-term trusts. trust is determined to be the best vehicle, it will add great value down the road if the corporate trustee is a “global" trustee, has experience with U.