Abusive tax schemes have evolved from simple structuring of abusive domestic and foreign trust arrangements into sophisticated strategies that take advantage of the financial secrecy laws of some foreign jurisdictions and the availability of credit/debit cards issued from offshore financial institutions. Generally, these schemes are characterized by the use of all of the following flow-through entities except:

A. International Business Companies

B. Foreign Trusts

C. Qualified Intermediaries

D. Foreign Partnerships