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In Reply to: plr 9630034 posted by greg seigel on 11/25/03:
David Goldberg e-mailed me about how you can tell whether an asset constitutes U.S. situs property for estate tax purposes. The rules on this are at IRC Sections 2104 and 2105. They apply unless they are varied by treaty. Where there is a treaty, the taxpayer can choose to use the treaty rules or the Code, whichever results in the lower tax.
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