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The Cross-Border Advisor Series · Book 2 · To be published in mid‑December 2026

U.S. Assets of Nonresident Aliens

A Guide for Financial Advisors

A guide for the advisors of non-U.S. clients who hold assets in the United States. The book determines which assets are U.S. property for the estate and gift tax of a nonresident alien and how the estate tax treaties change the statutory result, then treats each class of asset in turn: brokerage accounts, real estate, life insurance and annuities, digital assets, joint accounts, closely held business interests and art. It continues with the U.S. business of a European family, the nonresident’s own return and refund claims, and the administration of the estate when the client dies.

Forthcoming. To be published in mid-December 2026. Pre-orders are accepted now.
AuthorCaroline E. Ashford, PhD, JD
Publication dateMid-December 2026
ExtentAbout 540 pages; 24 chapters in six parts
LanguageEnglish
PriceUSD 225
SeriesThe Cross-Border Advisor Series, Book 2 of 6
OrderingPre-order through the form on this page or by email to info@clarisonpress.com
Pre-orderContents

Summary

  1. 1.Situs asset by asset, the estate tax of the nonresident alien with its $60,000 exemption equivalent, and the gift tax on transfers by a nonresident donor.
  2. 2.The estate and gift tax treaties as the rule for this readership, with a treaty map of all treaty partners and a chapter on reading an estate tax treaty.
  3. 3.The brokerage account: withholding on dividends and interest, securities gains, the documentation file and the estate tax on U.S.-situs securities.
  4. 4.U.S. real property from purchase to sale, FIRPTA, and blocker structures for securities and real estate, with the income tax treaty rates that price them.
  5. 5.The U.S. subsidiary of a European family business, the U.S. LLC as the tax systems of the five countries see it, and partnership interests held by foreign persons.
  6. 6.The nonresident’s Form 1040-NR and refund claims, and the estate of the nonresident client: the timeline, Form 706-NA, the federal transfer certificate and double taxation relief.

Readership

The book is written for financial advisors, including wealth managers, private bankers and foreign advisers, who serve non-U.S. clients holding assets in the United States.

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.

Townhouses on a New York street in autumn

The Six 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. Situs and the Two Transfer-Tax Regimes

2Situs: What Is and Isn’t U.S. Property

3The Estate Tax of the Nonresident Alien: The $13,000 Credit, the $60,000 Exemption Equivalent and the Conventions That Modify the Statutory Result

4Reading an Estate Tax Treaty

5U.S. Gift Tax on Nonresidents

III

Part III. Investing In and Holding U.S. Assets

6U.S. Brokerage Accounts of Nonresident Aliens: Withholding on Dividends and Interest, Securities Gains, the Documentation File and the Estate Tax on U.S.-Situs Securities

7U.S. Real Property of Nonresident Aliens: Acquisition, Rental, Sale, Gift and Inheritance

8FIRPTA: Withholding on Sales of U.S. Real Property by Foreign Persons and Foreign Estates

9Blocker Structures for U.S. Securities and Real Estate

10U.S. Life Insurance and Annuities Payable to Nonresident Aliens

11Digital Assets and Cryptocurrency Held at U.S. Institutions

12Jointly Held Accounts and the Consideration-Furnished Rule

13State Death and Income Taxes for Non-U.S. Persons

14Closely Held U.S. Business Interests Passing to Foreign Heirs

15Art, Collectibles and Tangible Personal Property

IV

Part IV. Doing Business in the United States

16The U.S. Subsidiary of a European Family Business: Entity Choice, the Owners’ Estate Exposure and Treaty Positions

17The U.S. LLC as Seen by Foreign Tax Systems: Hybrid Mismatches Compared

18Partnership Interests Held by Foreign Persons: Sections 1446(a), 864(c)(8) and 1446(f)

V

Part V. The Nonresident’s Own Return and Refunds

19The Nonresident’s Own Return: Form 1040-NR, the Net Election for Real Property Income, Treaty-Based Return Positions and the ITIN

20Refunds of Over-Withheld U.S. Tax: The Claim on Form 1040-NR or Form 1120-F, the Foreign Certificate of Residence and the Time Limits

VI

Part VI. When the Nonresident Client Dies

21The Administration of the Cross-Border Estate: Timeline, Deadline Grid and Checklist

22Form 706-NA in Practice

23The Federal Transfer Certificate

24Double Taxation Relief: Death Tax Credits and Treaty Mechanisms

Pre-order

U.S. Assets of Nonresident Aliens 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