Foreign Investment into the U.S. – Part II: Who is a U.S. Person?

The U.S. income tax and estate tax both function under a system with only two possibilities, a taxpayer is either a U.S. person / domiciliary or not a U.S. person, referred to as a non-resident alien (“NRA”).  There is no middle ground, it is an all or nothing system.  Since U.S. tax law is based […]