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The foreign reverse hybrid and the estate tax by Seth J. Entin

By: Entin, Seth J.
Material type: ArticleArticlePublisher: 2021Subject(s): EXTRANJEROS | INVERSIONES | INSTRUMENTOS HÍBRIDOS FINANCIEROS | NO RESIDENTES | IMPUESTO SOBRE EL PATRIMONIO | ESTADOS UNIDOS In: Tax Notes International v. 101, n. 10, March 8 2021, p. 1255-1261 Summary: In this article, the author 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.
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Resumen.

In this article, the author 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.

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