International Income and Estate Tax Planning for Cross-Border Clients

The Legal Intelligencer

By Justin H. Brown and Brittany A. Yodis
May 3, 2023

As noncitizens and nonresidents of the United States have increasingly acquired global assets, they may unknowingly be subjecting themselves to various income and transfer tax laws across multiple jurisdictions. The United States has specific income tax rules for noncitizen nonresidents (NCNRs), and it has an entirely different estate and gift tax regime for NCNRs, creating traps for the unwary cross-border client.

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