Since the final rule of August 2026, only foreign companies registered in a U.S. state report their non-U.S. beneficial owners to FinCEN. Banks, the IRS, New York and the Common Reporting Standard still identify the owners of family structures.
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
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