Estate Taxation of Nonresident Noncitizens: A Primer
Bridget J. Crawford
Pace University School of Law
Pace University - School of Law
Jonathan G. Blattmachr
Milbank, Tweed, Hadley & McCloy LLP
August 15, 2011
Tax Notes, Vol. 132, p. 759, August 2011
This article provides an overview of the U.S. estate tax rules that apply to nonresidents who are not U.S.citizens. The long arm of the U.S. federal estate tax extends to individuals who have assets located in the United States even if the individual is neither a resident nor a citizen of the United States. The statutory framework of subchapter B of chapter 11 of the Internal Revenue Code ode is not well understood, even by specialists. Those Code sections are not taught in most law school courses in federal estate and gift taxation. In light of the staggering staggering amount of foreign investment — $1,245.7 billion of financial assets (excluding derivatives) in 2010 — the estate tax rules governing nonresident noncitizens deserve attention.
Number of Pages in PDF File: 6
Keywords: estate tax, nonresident, noncitizen, foreigner, gross estate, foreign, resident, citizen
JEL Classification: K34Accepted Paper Series
Date posted: August 19, 2011
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