Under the current tax system, the United States imposes three types of transfer taxes: estate, gift and generation-skipping. U.S. citizens and resident aliens (RAs) are subject to estate tax on worldwide assets and are similarly taxed on worldwide gratuitous transfers for gift tax. U.S. citizens are subject to transfer taxes even if they never lived in the United States. If an individual isn’t a U.S. citizen or RA, then not all assets will be subject to those taxes. However, it remains
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