Hi, I have read several documents from the IRS about what is deemed a US-situs asset for US Estate Tax purposes for non-citizen and non-residents of the US. However there are 3 classes of assets that are not referenced anywhere and I would greatly appreciate if you could share your views on whether these would be considered US-situs or not for US Estate Tax purposes:
- US dollar cash in a foreign (outside of the US) brokerage account
- US corporate bonds and US CDs in a foreign (outside of the US) brokerage account
- a foreign US dollar money market fund (domiciled outside the US) and trading on a non-US stock exchange
Thank you !
Jo
US-situs assets for US Estate Taxes for foreigners
Moderator: Mark T Serbinski CA CPA
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Re: US-situs assets for US Estate Taxes for foreigners
1. US cash, even if held in US is NOT US situs, unless it is connected to a business.
2. the bonds would be, the CDs would not.
3. NOT US situs
2. the bonds would be, the CDs would not.
3. NOT US situs
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing
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Re: US-situs assets for US Estate Taxes for foreigners
Thank you for the information.
For item (2), would US Corporate Bonds held in a foreign brokerage account, and which are tax exempt in the interest generated to a non-US person be considered US-situs ? The information from the IRS mentions that Corporate Bonds which are tax exempt to non-US persons are not US-situs, but doesnt go on to explain if this is also the case if held in a foreign brokerage firm.
Jo
For item (2), would US Corporate Bonds held in a foreign brokerage account, and which are tax exempt in the interest generated to a non-US person be considered US-situs ? The information from the IRS mentions that Corporate Bonds which are tax exempt to non-US persons are not US-situs, but doesnt go on to explain if this is also the case if held in a foreign brokerage firm.
Jo
Re: US-situs assets for US Estate Taxes for foreigners
If they are considred not US situs when held within US, then they are not US situs when held outside US.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing
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- Joined: Tue Oct 02, 2018 7:18 am
Re: US-situs assets for US Estate Taxes for foreigners
yes that makes perfect sense.
Thank you again.
Jo
Thank you again.
Jo