Insights
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Partners Dina Kapur Sanna of the Individual Clients department and Stephen Ziobrowski of the Corporate and Business Law department recently authored an article in the UK Journal of International Tax, Trust and Corporate Planning. In "PFIC Considerations for Foreign Investors with US Beneficiaries," Dina and Stephen write that "the best approach for dealing with PFICs is to examine the portfolio of a non-resident alien or foreign trust any time a child or other beneficiary moves to the USA or is thinking of moving to the USA. There are a variety of strategies available to avoid the harsh results of the PFIC regime, so advance planning is critical."