New HIRE Act Affects Those With Foreign Asset Protection Trusts

Many U.S. taxpayers have established offshore trusts for asset and lifestyle protection reasons. Generally, offshore asset protection trusts (APTs) are set up to be “tax neutral,” such that the settlor pays a fixed amount of income tax on the income earned inside the APT. Often, these trusts contain assets such as boats, planes, and other luxury items, including substantial cash and securities. The trustee of an APT can make the APT assets available for use or loan to U.S. persons not otherwise designated as […]

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