Articles and Guides
For Fiduciaries
So You Are the Executor: A Personal Representative’s Guide to a Cross-Border Estate
A practical, plain-language guide for the person named executor or personal representative of a cross-border estate — what personal liability you carry, why accounts freeze, and the sequence that gets a two-country estate through safely.
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When an Immigrant Owns a Foreign Company: CFC, Subpart F, GILTI (Now NCTI), and Form 5471
A technical guide for U.S. advisers on how a foreign company owned by an immigrant client can become a controlled foreign corporation the moment U.S. residence begins — current Subpart F and net-CFC-tested-income (NCTI) inclusions, the §962 election, and mandatory Form 5471 reporting.
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The Accidental American: Compliance and the Path to Renunciation
A guide for advisers to the client who is a U.S. citizen by birth or descent but has lived an entirely non-U.S. life — how FATCA surfaces the problem, the compliance pathways (Streamlined Foreign Offshore, Relief Procedures for Former Citizens, delinquent submissions), the renunciation process, and the covered-expatriate screen that must run before any oath.
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Ancillary Probate and Administering a Nonresident’s U.S.-Situs Assets
A guide for advisers on administering a nonresident’s U.S.-situs assets — the two gates of ancillary probate (state-court authority) and federal tax clearance (Form 706-NA and the transfer certificate), the foreign executor’s statutory duties, applicable estate tax treaties, and how to sequence a multi-jurisdiction administration.
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Investing in U.S. Securities as a Non-U.S. Person: What You Need to Know
A guide for the non-U.S. investor on the three regimes governing a U.S. brokerage account: dividend withholding and treaty rates, the capital-gains advantage, and the estate-tax trap that can freeze the account and expose it to tax at up to 40% on death.
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