Coping with PFIC and Trust Issues in Today’s Environment - New York

New York, NY

Price: $795

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Join us for this new, one-day beginner to intermediate seminar with live group instruction combining two aspects of U.S. taxation particularly relevant to cross border structures: Trusts and Passive Foreign Investment Companies (PFICs).

Trusts have long been favored vehicles for structuring investments and protecting assets.  The classification of a foreign entity as a Passive Foreign Investment Company (“PFIC”) for U.S. tax purposes presents several significant issues for its U.S. shareholders.  

A discussion of these two U.S. tax topics implicated in cross border investments should prove extremely worthwhile for individuals working with cross border structures.  This seminar provides technical discussion regarding the background of these two topics, as well as planning for the challenges in these far reaching areas in today’s environment.

•  Understand the main aspects of the U.S. Federal income taxation of trusts
•  Explain the definitional issues associated with the federal tax classification of trusts
•  Discuss the main attributes of foreign entities qualifying as Passive Foreign Investment Companies (PFICs) and the implications to U.S. investors
•  Discuss the need for consideration of PFIC issues when structuring trusts with U.S. and non-U.S. parties
•  Appreciate the overall Federal tax filing requirements associated with PFICs and trusts
•  Discuss the potential PFIC implications and pitfalls stemming from recent events and developments
•  And more!


Bloomberg BNA has developed this new, one-day seminar discussing two significant tax topics impacting cross border structures and investments:  1) trusts and 2) Passive Foreign Investment Companies (“PFIC”).

Many cross border corporate structures as well as investment strategies for high net worth family investments often implicate PFIC issues.  The applicability of the trust and PFIC rules is far reaching and the failure to stay abreast of their intricacies may be costly.

The complexity of these two areas and their far reaching impact cannot be overstated.  The need for continued vigilance with regard to these issues is only increased by recent events.

This seminar is intended for accountants, tax advisers, attorneys and other financial executives looking to develop an understanding of how the US tax rules pertaining to trusts and PFICs intersect in the areas of cross border investment.  No prerequisite is required for this introductory seminar with live group instruction. This program is transitional which is appropriate for newly admitted attorneys.


8:30 AM  Registration and Continental Breakfast

9:00 AM  Introduction and Chairpersons Opening Remarks

9:15 AM  The “Trust” Essentials
• Definitional and classification issues, e.g. grantor trust, nongrantor trust, domestic vs. foreign
• Cross border scenarios, e.g. NRA grantor trust with US beneficiaries, Foreign non-grantor trust with NRA beneficiaries
• Overview – US filing requirements

10:30 AM  Coffee Break

10:45 AM  The Use of Trusts in Investment Structures
• Using trusts in estate and gift tax planning for high net worth families
• Implications of the “throwback” rules
• US tax issues for foreign trusts with US beneficiaries

12:15 PM  Luncheon

1:00 PM  PFIC Requisites
• PFIC Classification issues; e.g. the income and asset tests, the “look through” rules, consequences of excess distributions
• Applicability and consequences of elections, e.g. the “QEF” election, the “mark to market” election
• Overview – US filing requirements

2:45 PM  Coffee Break

3:00 PM  Trust Structures Implicating PFICs
• PFIC consequences of Investment structures involving trust entities
• Planning to avoid PFIC classification

4:00 PM  Discussion of Current Issues Impacting PFICs and Trusts
• Increased applicability of PFIC classification issues
• IRS scrutiny of trust structures and the applicability of the PFIC regime
• Increased disclosure and compliance

5:00 PM Seminar Concludes



October 24, 2016


AMA Conference Center  
1601 Broadway (at 48th and Broadway)
8th Floor
New York, NY 10019

Hotel accommodations are at your own discretion. We suggest the following: 

Belvedere Hotel
319 West 48th Street
New York, NY 10036
Tel: (212) 245-7000

Novotel of New York
226 West 52nd Street
New York, NY 10019
Tel: (212)-315-0100  



If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution. To request a transfer, contact with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event. 

Cancellations must be made in writing to more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event. For more information regarding administrative policies, complaints and cancellations, please contact us at 800.372.1033, or e-mail


Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at

Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.


Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.