Steps Foreign Persons Can Take To Avoid Unnecessary U.S. Estate Tax

A recent CNBC report suggests that several billion dollars of estate tax due from the estates of foreign decedents on investments in U.S. stock and real estate goes uncollected by the IRS every year.  The report noted a large discrepancy between the amount of foreign investment in these assets and the number of estate tax returns filed by foreign individuals reporting such assets.  To avoid liability for unpaid taxes, U.S. banks, brokerages, and other custodians must obtain certification from the IRS that a foreign account holder has complied with U.S. tax laws before transferring the proceeds of the account at the account holder's death.  However, according to the CNBC report, foreign banks have assisted their clients in keeping the IRS from learning about generational transfers of wealth through tactics such as holding stock in the financial institution's name, so that U.S. brokerages are not aware of the ultimate owners' identities.  The report speculates that these