Your client is moving to the USA
It happens to the best of us. A European or Latin American family office or bank has a key client who calls one day to advise that they have decided to move to the USA. Unless the institution is SEC registered they will almost certainly have to relinquish the client.
No they won't. We can structure the client's assets into a US compliant Private Placement life insurance or annuity policy that can hold all their existing investments including PFIC's and will allow the current bank and asset manager to continue in their roles. Better still, the policy can be completely tax-free for the client.
We have solved this problem many tens of times and have a large book of totally compliant and satisfied US resident clients. Why not contact us to see how we can help?