Days after the IRS announced a new "revenue procedure" it said would "exempt from foreign trust information reporting requirements certain U.S. individuals' transactions with, and ownership of, certain tax-favored foreign trusts", some tax experts have been coming forward to express doubts about whether the new "procedure" would achieve much, if anything.

It is perhaps not surprising to hear that non-U.S. (or "foreign") trusts with U.S. owners can be tricky...