Summary A person who is neither a United States citizen nor domiciled in the United States is taxed at death on United States situs property alone, but against an exemption of only $60,000 and a top rate of 40 percent. The exemption for a citizen or a domiciliary in 2026 is $15,000,000. Situs is decided asset by asset, and the
Read moreAn American citizen or green card holder is taxed by the United States on income from every source in every country, for as long as the status lasts and wherever the person lives. The assets themselves are usually held in the forms that are ordinary where they sit: a Luxembourg fund, a German GmbH, a French assurance-vie, a Swiss occupational
Read moreSummary A non-citizen who has become domiciled in the United States is taxed at death on the worldwide estate, exactly like a citizen, and has the same $15,000,000 exclusion in 2026. The green card is not what decides this. What such a person does not have is the unlimited marital deduction. Property passing to a spouse who is not a
Read moreA United States citizen, or a person domiciled in the United States, is taxed at death on everything owned anywhere: the apartment in Munich, the account in Geneva, the pension accrued in London. The plan meant to govern those assets is not similarly unified. Succession is territorial, and every country in which property sits runs its own proceeding, applies its
Read moreSummary Asset protection is the arrangement of title, insurance, entities and trusts before any claim arises. It is lawful only while the client is solvent, before a claim is foreseeable, and with full tax reporting. Every transfer remains subject to voidable transfer law and the Bankruptcy Code. Transfers to a self-settled trust made with intent to hinder creditors can be
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