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"Foreign individuals (called nonresident alien individuals by the IRS) are subject to U.S. estate taxes ...And since foreign individuals only get a $60,000 exemption from u.s. estate taxes on their U.S. holdings, a wealthy foreigner could lose more than half his wealth to the IRS when he dies, unless he plans carefully."...Comments, anyone...

Well. Estate taxation of non-resident aliens is wayyyy out of my area, but you could check out the instructions to Form 706 NA

"Form 706-NA is used to compute estate and generation-skipping transfer (GST) tax liability for nonresident alien decedents. The estate tax is imposed on the transfer of the decedent's taxable estate rather than on the receipt of any part of it. "


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