Similar Posts


  1. @Paul,

    I would agree with you. Section 1022(c) should give a step up in basis in situations where a nonresident has the bad judgment to die in 2010. (For those of you unfamiliar with the situation, Section 1022 is the carry-over basis rule that applies for 2010 while the estate tax has evaporated.) If the logic holds true that Section 1014 gives step up in basis, why shouldn’t Section 1022 work the same way?

    This is pure speculation fueled by common sense and a liberal dose of caffeine, but it’s my best opinion as of 3:41 Pacific Daylight Time on a Thursday, and I’m sticking with it.


  2. Some early commentators, without citation, have suggested that the spousal basis adjustment available to spouses under 1022(c) will not apply to NRAs. Seems like it should. Any thoughts?

Comments are closed.

Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.