Article on Estate & Gift Taxation of Nonresidents

John R. Strohmeyer recently published an Article entitled, Estate and Gift Taxation of Nonresidents, November/December Probate & Property (2016). Provided below is an abstract of the Article:

The digital economy makes it easy for people and money to move across international borders. If the United States is not involved, then this movement will not have an effect on a person’s U.S. tax situation, and in general a nonresident of the United States will have few, if any, interactions with the IRS. But as more and more foreign citizens look to the United States as a place to invest, it becomes important for planners to be aware of the transfer tax laws that apply to nonresidents. Why? When a nonresident becomes a “resident” of the United States for transfer tax purposes, the rules change dramatically, and the tax consequences, if not planned for, can be severe.