Calling for Clarity On NRAs' Partnership Situs

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