Advisors to U.S. clients increasingly are faced with questions regarding the U.S. gift, estate, generation skipping transfer (GST) and income tax consequences of transfers from non-resident aliens to, or for, the benefit of their U.S. clients. Most advisors are familiar with the tax treatment of gifts, inheritances and distributions from U.S. donors, decedents and trusts. But the tax treatment of transfers from foreign individuals, estates and trusts to U.S. recipients differs in many
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