Two recent international developments have raised concerns among professionals in the international tax and estate planning communities about the continued viability of utilizing the traditional so-called offshore tax havens or structured product jurisdictions such as the British Virgin Islands, Cayman Islands, Ireland, Isle of Man, Jersey, Liechtenstein, Luxembourg, the Netherlands and Panama for trusts and family or private-interest foundations.

These concerns have caused international practitioners and their clients to consider moving trust assets to the United States and the use of trusts formed in the United States and governed by protective state laws, like those of Nevada and Delaware, with U.S. resident trustees.