The firm provides detailed planning advice to United States citizens living outside of the country, non-citizens living in the country, or owning foreign property, and non-citizens living outside of the United States with investments in this country. Kohnen and Patton’s lawyers, working with clients’ other foreign or domestic professionals, advise on any cross-border property succession or transfer tax issues involving the U.S.

Services include:

  • Designing the U.S. component of a cross-border wealth transfer plan. The plan provides for the succession of property and the legitimate avoidance or reduction of the various U.S. transfer taxes: Inheritance, gift, estate and generation-skipping taxes
  • Assisting international families of persons who have died holding U.S. assets with preparation of U.S. transfer tax returns, applications for U.S. Transfer Certificates and the preparation of documents required by U.S. transfer agents, banks, brokerage houses and U.S. probate courts in accomplishing Succession Transfers
  • Advising clients about the U.S. Expatriation Exit Tax and planning for its legitmate avoidance or reduction.
  • Structuring the ownership of U.S. Immovables (real estate)


Persons residing in any of the following countries (who are neither U.S. citizens nor “long term” U.S. residents) and citizens or residents of any of the countries listed below who reside in the U.S., but are not “long term” U.S. residents, should review the general provisions of the applicable treaty.  The treaties vary as to the time period that one must reside in the U.S. before becoming a “long term” U.S. resident.

In most instances, the estate tax imposed at death by the U.S. will reduce the estate tax, if any, imposed by each of these treaty countries.

  • Australia
  • Austria
  • Canada
  • Denmark
  • Finland
  • France
  • Germany
  • Greece
  • Ireland
  • Italy
  • Japan
  • Netherlands
  • South Africa
  • Switzerland
  • United Kingdom

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