NRNCNew Roofs for a New Century
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The results can be even further improved if the surviving spouse is an NRNC who does not own property situated in the United States.
Example 4: Assume the same facts as Example 2--but the surviving spouse is an NRNC with $10 million of property (as of the first deceased spouse's death) not situated in the United States for estate tax purposes, and who never becomes a U.S.
For example, an NRNC went to a California lawyer to have a revocable trust document prepared to dispose of her U.S.
Fur estate tax purposes, an NRNC is generally liable for transfer taxes only when the properties transferred have situs within the United Slates.
Property that is gratuitously transferred by an NRNC decedent while he or she is alive, in which the NRNC was deemed to have an interest at death by being subject to a certain type of transfer, or had certain rights or powers over the property (within the meaning of Sec.
situs intangible property by an NRNC are generally exempt from the gift tax.
When an NRNC wishes to purchase real estate in the United States, tax planning should be undertaken u) determine if there's an acceptable alternative to purchasing it outright that would avoid either gift or estate tax.
museum, this transaction caused the NRNC to owe significant gift tax.