The Foreign Reverse Hybrid and the Estate Tax

Tax Notes International

7 Pages Posted: 9 Mar 2021

Date Written: March 8, 2021


In this article, the author demonstrates that
the estate of a foreign individual who dies
owning an interest in a foreign reverse hybrid
entity is not subject to U.S. federal estate tax in
connection with an interest in the entity, even if
the entity owns U.S.-situs assets.

Keywords: international estate tax nonresident situs check box partnership

Suggested Citation

Entin, Seth J., The Foreign Reverse Hybrid and the Estate Tax (March 8, 2021). Tax Notes International, Available at SSRN:

Seth J. Entin (Contact Author)

Greenberg Traurig ( email )

333 S.E. 2nd Avenue
44th Floor
Miami, FL 33131
United States
305-579-0615 (Phone)

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