Globe - There have been a lot of schools of thought on this one....I personally believe that it will be a non-issue. Here's why:
You are being given a piece overseas land, the value of which is being held in an overseas trust(The foundation). No true monetary value enters the U.S. unless you allow the foundation to sell your land and have your gains sent to you here in the U.S. It is entirely an overseas transaction. All a PDR truly is is a receipt saying that something held in or deposited to the foundation belongs to you. All this IMO...I'm many things, but NOT a tax guy.