Case study 1
Frozen US brokerage account released after a transfer certificate
The family could not touch a US investment account months after the death, and the custodian would say only that it needed a certificate. We inventoried the estate by situs, valued the US holdings as at the date of death, prepared and filed the US return, then made the certificate request with the assessment behind it. The engagement produced a filed return, a documented situs analysis for every asset in the account, and the certificate the custodian required before the transfer. The family also had, for the first time, a written explanation of why the account had been frozen at all.
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Case study 2
Sunbelt condominium owned personally by a Canadian who filed nothing
A holiday property had been bought many years earlier and held in the owner's own name. Nothing had ever been filed in the United States, and the executor had been told, wrongly, that there was no exposure because the owner was not American. We established the situs position, obtained a valuation of the property as at the date of death, computed the exposure against the exemption a non-resident is allowed, and set out the treaty relief claim alongside it. The work produced a filed US return and a written basis for the proportion used in the relief computation.
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Case study 3
Situs analysis that kept most of an estate outside the US net
The estate looked heavily exposed because most of the portfolio carried American names. Working through the holdings one at a time, we distinguished the items genuinely situated in the United States from those that were not, and recorded the reasoning against each line. The exposure that remained was far narrower than the first pass had suggested. The engagement produced a classified inventory, a return covering the assets that did fall inside it, and a memorandum the executor could hand to the custodian and to the beneficiaries who had been told the whole portfolio was caught.
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Case study 4
Executor who had already distributed before the US exposure surfaced
Part of the estate had gone out to beneficiaries before anyone identified the US assets. We stopped further distributions, reconstructed the estate as it stood at the date of death, established what the US position should have been, and prepared the return on that basis. Where funds had to be recovered to meet the liability, we set the position out in writing so the executor could approach the beneficiaries with a document rather than an apology. The engagement produced a filed return, a settled exposure, and a record of the sequence that the executor needed for personal protection.
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Case study 5
Rebuilding a deduction schedule after the first computation overstated it
An earlier adviser had taken the deceased's liabilities and funeral costs in full, as though the estate were an American one. We reworked the computation on the restricted basis that applies to a non-resident estate, allocated each item against the US property where an allocation was required, and evidenced every figure to a source document. The result was a smaller deduction than the family had been promised, and a defensible one. The engagement produced a corrected return, a schedule tying each liability to its evidence, and a note on the items that could not be claimed at all.
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Case study 6
Reworking how US holdings were held while it could still be changed
A client in good health wanted the position understood while it was still open to change. We measured the proportion of the worldwide estate that sat in US-situs assets, showed how that proportion drives both the tax and the pro-rated treaty credit, and set out the ways the same investment exposure could be carried without the same situs footprint. Nothing was implemented on our analysis alone; it went to the client's lawyer and investment adviser. The engagement produced a written memorandum, a revised asset schedule, and a shorter list of holdings that would freeze on death.
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Case study 7
A Non-Resident Estate Holding US Assets
US situs assets sit inside the US estate tax net regardless of where the owner lived, and the exemption available to a non-resident is not the resident one. The file establishes situs asset by asset before any relief is claimed.
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Case study 8
One Salary, Two Countries Claiming It
A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.
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