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The Cross-Border Advisor Series · Book 1 · To be published in mid‑December 2026

Tax and Estate Planning for Non-Citizens in the United States

A Guide for Financial Advisors, Tax Advisors and Estate Planners

A guide for the advisors of non-citizens who live in the United States: green card holders, visa holders and their families, as clients and as heirs. The book follows the client from the tests that decide income tax residence and estate tax domicile, through arrival, holdings in the home country, work in the United States and marriage to a spouse who is not a U.S. citizen, to inheritances received in the United States and the return home. The income tax treaties and the estate and gift tax treaties are applied throughout as the rule.

Forthcoming. To be published in mid-December 2026. Pre-orders are accepted now.
AuthorCaroline E. Ashford, PhD, JD
Publication dateMid-December 2026
ExtentAbout 530 pages; 24 chapters in eight parts
LanguageEnglish
PriceUSD 225
SeriesThe Cross-Border Advisor Series, Book 1 of 6
OrderingPre-order through the form on this page or by email to info@clarisonpress.com
Pre-orderContents

Summary

  1. 1.Status first: the green card test and the substantial presence test, the domicile test of the estate and gift tax, the effect of each visa category, and domicile between the states.
  2. 2.The treaty grace periods for new arrivals from Germany, France and the United Kingdom, and the compliance of the arrival and departure years, including the dual-status return.
  3. 3.Pre-immigration planning and the reporting that begins with residence: FBAR and Forms 8938, 5471, 8865, 8621 and 3520.
  4. 4.Holdings in the home country: foreign companies under the CFC rules, foreign real property, foreign pensions and life insurance, foreign trusts, and the U.S.-resident successor of a European family business.
  5. 5.The spouse who is not a U.S. citizen: lifetime gifts, the marital deduction, the qualified domestic trust, the treaty marital relief, and naturalization as the complete answer.
  6. 6.The resident alien as heir and beneficiary, gifts and bequests from covered expatriates under section 2801, and the departure from the United States with the accounts left behind.

Readership

The book is written for financial advisors, tax advisors and estate planners whose clients are green card holders, visa holders and their families, both as clients and as heirs.

Foreign law is treated comparatively for five countries: Germany, France, Switzerland, Italy and the United Kingdom. The applicable tax treaty is treated as the rule rather than the exception.

The book stands alone. Its first chapter, on status, situs, the treaties and the reporting forms, is shared by the six books of the Cross-Border Advisor Series and adapted to the readers of each. Where another book of the series treats a rule in full, this book carries a working summary of the rule or refers to that book by short title and section.

A U.S. permanent resident card in front of the American flag

The Eight Parts

Chapter titles as planned; they may change before publication. The book also carries a preface, a page on the companion books, a table of abbreviations, a figures appendix, a bibliography, a table of authorities and an index.

I

Part I. Foundations

1Foundations: Status, Situs, the Treaties and the Reporting Forms

II

Part II. Who Is Resident, and Who Is Domiciled

2Residence and Domicile: The Two Tests

3How Visa and Immigration Status Shape U.S. Tax Residency

4The Transfer-Tax Domicile of Visa Holders and Green Card Holders, with State Domicile

5Treaty Grace Periods for New U.S. Domiciliaries: Germany’s Ten Years, France’s Five of Seven, the United Kingdom’s Seven of Ten

6Arrival and Departure Compliance: Dual-Status Years, Treaty-Based Return Positions and the Departing Alien

III

Part III. Arrival and Worldwide Taxation

7Pre-Immigration Planning

8The Green Card and Worldwide Taxation: The Income, Estate and Gift Tax Position of the Resident Alien

9The Individual Foreign-Asset Reporting Calendar for New Residents: FBAR, Forms 8938, 5471, 8865, 8621 and 3520

IV

Part IV. Holdings Abroad

10When an Immigrant Owns a Foreign Company: CFC, Subpart F and NCTI

11Foreign Real Property and Other Foreign-Situs Assets of a U.S. Resident: The Asset Country’s Limited Tax Liability, the U.S. Income and Transfer Taxes and the Conventions

12Treaty Relief Abroad for the U.S. Resident: Form 8802, the Certificate of Residence on Form 6166 and the Reclaim of Foreign Withholding Tax

13The U.S.-Resident Successor of a European Family Business: The Business-Property Reliefs of the Five Countries, the Inherited Company Under U.S. Law and the Successor’s Later Departure

14Foreign Pensions, PPLI and Foreign Life Insurance in the Hands of a U.S. Person

15Foreign Grantor and Nongrantor Trusts with U.S. Touchpoints

16Irrevocable Trusts for the Immigrant Taxpayer

V

Part V. Working in the United States

17Working in the United States: Equity Compensation, Founders, Secondments and Totalization

VI

Part VI. The Non-Citizen Spouse

18The Non-Citizen Spouse: Lifetime Gifts, the Marital Deduction, QDOTs and Treaty Relief

19Green Card or Naturalization: The Transfer-Tax Case for Citizenship

VII

Part VII. The Resident Alien as Heir and Beneficiary

20The U.S. Resident as Heir of a Foreign Estate or Beneficiary of a Foreign Trust

21Forms 3520 and 3520-A: Foreign Trusts and Large Foreign Gifts

22The Resident Alien as Beneficiary of U.S. Accounts, Estates and Trusts

23Section 2801: Gifts and Bequests from Covered Expatriates

VIII

Part VIII. The Return to the Home Country

24The Departing Non-Citizen: The Green Card, the Last U.S. Tax Year and the U.S. Accounts Left Behind

Pre-order

Tax and Estate Planning for Non-Citizens in the United States is to be published in mid-December 2026. Price: USD 225 a copy. Each pre-order request is confirmed by email, with the shipping costs and the method of payment.

Contents, price and publication date may change. The cover shown is provisional. Trade and bulk orders: info@clarisonpress.com

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The Cross-Border Advisor Series

The Other Books in the Series

Six numbered books for professionals who advise clients with assets, residences, heirs or trusts in more than one country, each published and sold on its own. The series