In a June 23 memorandum to Treasury’s assistant secretary for tax policy, the American College of Trust and Estate Counsel (ACTEC) submitted proposals for future Treasury guidance coordinating the foreign corporation anti-deferral rules with the trust taxation provisions found in subchapter J of the code. October 11, 2010.Download
10/2010
ACTEC Proposals Integrate Subchapter J, PFIC Regime for Foreign Trusts
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Stephen K. Vetter
