There are various theories proposed for determining situs of partnership interests for U.S. federal estate tax purposes when those interests are held by a non-resident alien (NRA)1 and the partnership is a domestic (U.S.) partnership or holds U.S.-situs assets or conducts business in the United States.2 When no applicable bilateral estate tax treaty speaks to the issue,3 there's a good deal of uncertainty about situs due to a lack of guidance in the Internal Revenue Code and Treasury ...

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