PRACTICE AREA
Cross-Border Inheritance Matters
U.S. Tax Counseling for International Inheritances and Cross-Border Estates
When a family member passes away and assets, heirs, or both span multiple countries, the U.S. tax implications can be significant — and easy to miss without specialized counsel. Cross-border inheritance matters sit at the intersection of U.S. estate tax, income tax, and international information reporting. For non-resident aliens who hold U.S.-situs assets at death, even modest holdings can trigger U.S. estate tax liability, banking freezes, probate proceedings, and IRS transfer certificate requirements — a system that is difficult to navigate without planning.
Our Services Include:
U.S. income tax analysis of foreign inheritances received by U.S. persons — including DNI, UNI, and throwback rules for foreign trust distributions
Form 3520 reporting for U.S. persons receiving gifts or inheritances from foreign persons or estates
U.S. estate tax analysis for non-resident aliens with U.S.-situs assets — including the limited $60,000 exemption and treaty-based relief
Form 706-NA preparation for nonresident alien decedents with U.S.-situs assets
IRS transfer certificate procedures for estates with frozen U.S. financial accounts
Probate and estate administration coordination for U.S.-situs assets owned by NRAs
Treaty-based estate tax analysis and planning for decedents in treaty countries
Planning for families with U.S. and non-U.S. members to minimize estate tax friction across generations