Nonresident Non-Citizen Asset Situs Exclusion
IRC §2103
Excludes property from the gross estate of a nonresident non-citizen if the property is not legally situated within the United States at the time of death.
Eligibility
Applies to nonresident non-citizens who structure their holdings to ensure assets (such as foreign stock or certain debt obligations) are not considered U.S.-situs property.
Frequently Asked Questions
Who is eligible for the Nonresident Non-Citizen Asset Situs Exclusion?
Applies to nonresident non-citizens who structure their holdings to ensure assets (such as foreign stock or certain debt obligations) are not considered U.S.-situs property.
How does the Nonresident Non-Citizen Asset Situs Exclusion work?
Excludes property from the gross estate of a nonresident non-citizen if the property is not legally situated within the United States at the time of death.
What law authorizes the Nonresident Non-Citizen Asset Situs Exclusion?
The Nonresident Non-Citizen Asset Situs Exclusion is authorized under IRC §2103 of the Internal Revenue Code (Title 26, United States Code).
Statutory Text — IRC §2103
Source: Internal Revenue Code, Title 26, United States Code
Legal Sources
US Code (Official) — 26 USC §2103 → Cornell Law Institute — 26 USC §2103 → Search IRS.gov for IRC §2103 → Treasury Regulations (26 CFR) →Discovered by: discovery_engine_v1
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