Perspectives

Analysis for families whose assets cross a border.

What the US tax code actually does to a non-US family, written with the statute open. No summaries of summaries, and no advice you could act on without a professional. The figures are checked, and where something is unsettled we say so.

Latest

Pay first, inherit second: Form 706-NA and the nine month deadline

Form 706-NA falls due nine months after the death, and the tax is payable in cash before the assets are released. What happens month by month.

August 1, 202615 min read

The trust you probably do not need: US life insurance requirements for foreign nationals
Under IRC 2105(a), proceeds on the life of a nonresident are not US-situs property. What carriers actually require to get there, and the trust most nonresidents do not need.
July 30, 202614 min read
The LLC you were told to set up answers a different question
A single-member US LLC is generally disregarded for estate tax, and no case or published ruling decides it either way. Which structures work, and what each one costs.
July 26, 202615 min read
Your Miami bank account is not taxed. Your US shares in Geneva are
For US estate tax a share sits where its issuer was incorporated, not where it trades or where the account is held. Cash in a US bank account falls outside the estate. Cash in a brokerage account does not.
July 21, 202613 min read
Nobody counts the days: who is a nonresident for US estate tax
For estate tax, the United States does not count days. It uses domicile, a test with no numbers in it, decided after you die. What defines it and what turns on the answer.
July 14, 202612 min read
Mexico Has No Estate Tax Treaty With the United States. Canada Does, and the Difference Comes Due in Cash
US estate tax for Mexican nationals: with no estate tax treaty, the exemption equivalent is $60,000 and the rate reaches 40%. The real numbers.
June 17, 202612 min read
Premium Financing for Foreign Nationals: What Changed When Money Stopped Costing 2%
Premium financing in 2026: SOFR at 3.65%, collateral calls that repeat, and why the lender will not accept the death benefit as the source of repayment.
May 21, 202618 min read
Your Heirs Have Nine Months to Find $332,800
Buy a Miami condo and your heirs owe $332,800 in US estate tax on $1,000,000, in cash, nine months after death. Here is the whole bill.
April 28, 202611 min read
The $60,000 Trap: US Estate Tax for Nonresident Aliens
US estate tax for nonresident aliens hits assets above $60,000 at rates up to 40%. How it is computed, which assets count, and what deadlines run.
April 9, 202614 min read

Analysis for families whose assets cross a border.

Pay first, inherit second: Form 706-NA and the nine month deadline

The trust you probably do not need: US life insurance requirements for foreign nationals

The LLC you were told to set up answers a different question

Your Miami bank account is not taxed. Your US shares in Geneva are

Nobody counts the days: who is a nonresident for US estate tax

Mexico Has No Estate Tax Treaty With the United States. Canada Does, and the Difference Comes Due in Cash

Premium Financing for Foreign Nationals: What Changed When Money Stopped Costing 2%

Your Heirs Have Nine Months to Find $332,800

The $60,000 Trap: US Estate Tax for Nonresident Aliens