Blocker Structures for U.S. Securities and U.S. Real Estate Held by Nonresident Non-Citizens

Description

An adviser’s guide to the situs rules that place a nonresident’s directly held U.S. shares and U.S. real property within the estate tax above a $60,000 exemption equivalent, the estate tax conventions that remove the securities exposure for domiciliaries of six countries and prorate the unified credit for nine, the foreign corporation as the residual answer for a securities portfolio, the single foreign corporation and the two-tier structure for real property, the income tax treaty rates that price them and their exit mechanics, the trust, partnership, leverage and insurance alternatives, the substance, personal-use and reporting disciplines that keep a structure effective, the home-country rules that reach the structure from the other side, and the restructuring owed to U.S.-person heirs. 23 pages. Updated in September 2026.