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Practice Areas > Estate Planning > Estate Planning for Non US Citizens

Persons who are not United States citizens, such as nonresident aliens and greencard holders, face a challenging United States estate tax planning environment when they invest in United States assets. Instead of the $2,000,000 exemption amount to which United States citizens and permanent residents are entitled, a nonresident alien is entitled to an exemption of only $60,000 for their United States property. Permanent residents of the United States, while entitled to the entire $2,000,000 estate tax exemption for the United States estate tax, are subject to United States estate tax on their worldwide assets, including assets held in the home country. Both nonresident aliens and greencard holders may also be subject to estate tax in their country of citizenship.

The United States has entered into an estate tax treaty with a select number of countries, including Australia, Austria, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, Netherlands, Norway, South Africa, Sweden, Switzerland, and the United Kingdom. These treaties, in general, allow a citizen of one of the treaty countries who owns property to avoid the possibility of both countries taxing the same asset at the time of death. As far as the United States estate tax is concerned, a treaty might reduce or eliminate such tax on the United States property of a nonresident alien.

Proper planning can greatly reduce the incidence of the United States estate tax for nonresident aliens and permanent residents, by taking advantage of certain structures and planning techniques, such as:

• Pre Immigration Planning
• Debt Financed Real Estate
• Offshore Trust Planning
  

The attorneys of Clark Skatoff ^PA have experience representing nonresident aliens and greencard holders with estate planning, particularly individuals from the “treaty” countries, Israel, and from the Caribbean, Central America, and South America.


To learn more about tax planning for nonresident aliens, please call 888-752-8633 or send one of our lawyers an email.