March 8, 2021

The Foreign Reverse Hybrid and the Estate Tax

Tax Notes International
Seth J. Entin

Tax Partner Seth Entin authored an article in Tax Notes International about whether a foreign individual’s estate is subject to U.S. federal estate tax if the entity owns U.S.-situs assets. In the article, he demonstrates that the estate of a foreign individual who dies owning an interest in a foreign reverse hybrid entity is not subject to U.S. federal estate tax in connection with an interest in the entity, even if the entity owns U.S.-situs assets.

READ: The Foreign Reverse Hybrid and the Estate Tax

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