In This Presentation:

- Basic Rules

- Determination of Residency for Estate Tax purposes

- Tax Rules

- Estate and Gift Tax Treaties

- Asset Situs Rules

- Taxation of Life Insurance and Annuities held by Non-US citizen

- Planning Strategies

- Gifting

- Joint Tenant Property Rules

- Foreign Death Tax Credit

- Using Qualified Domestic Trusts (QDOTs)

- QDOTs

- Alternative to QDOT

- Excerpt from Determination of Residency for Estate Tax purposes:

- Resident Alien Status

•U.S. income tax imposed on worldwide income

•US estate tax imposed on worldwide assets

- Nonresident Alien Status

•US income tax imposed only on income from the US

•US estate tax imposed on assets domiciled in the US or tangible property in the US

- Country of Domicile—a “facts and circumstances” test

- One can be a nonresident alien for income tax purposes, but not for estate tax purposes. Reverse could be true as well.