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ARTICLE · 12 DECEMBER 2025

Panama Private Interest Foundations: Structure And US Tax Classification

GGI | Global Alliance
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Panama Private Interest Foundations (PIFs) are hybrid entities – part trust, part corporation – created under Panama's Private Foundation Law of 1995.

United StatesTax

Overview

Panama Private Interest Foundations (PIFs) are hybrid entities – part trust, part corporation – created under Panama's Private Foundation Law of 1995. They are often used as vehicles for cross-border investments, but their unique nature creates complex US tax and reporting considerations that require careful planning.

What are PIFs?

PIFs are legal entities without shareholders, structured around a founder, a foundation council (like a board of directors), an optional protector, and beneficiaries named in the charter. Registered in Panama's Public Registry, PIFs can own assets, manage investments, and conduct business if profits support the foundation's purpose. 

Under Panama's territorial tax system, foreign-source income is exempt, making PIFs ideal for asset protection, estate planning, and confidentiality. Assets are separate from the founder's estate and shielded from creditors, while beneficiary identities remain private.

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