The foreign estate consists of multiple assets including stocks, real estate, and cash the sum total of which is below the US federal tax threshold of $12.06 million.
Can the inheritor, who is a resident US citizen, and a recipient of part of the estate, specifically stocks, act as executor as per the definition of “executor” in Form 706, and summarily change the valuation date for the entire estate? What is the objective of the US tax code here, to treat the foreign estate as if it were in the US even though there will be no consequence to the foreign estate?
It seems this scenario isn’t covered by section 2032(c).
