The nonresident aliens are subject to estate tax only on that part of the gross estate which at the time of death is situated in the U . S . Another significant distinction between U . S . citizens / RAs and NRAs is in the exemptions allowed in computing the tax liability.
22.
Life insurance proceeds are generally included in the gross estate if the benefits are payable to the estate, or if the decedent was the owner of the life insurance policy or had any " incidents of ownership " over the life insurance policy ( such as the power to change the beneficiary designation ).
23.
America's estate tax is levied at a high rate ( a marginal rate of 55 percent for the biggest estates ), but it kicks in only after a sizeable exemption ( in effect, the first $ 1 . 35 million of gross estate per couple, rising to $ 2 million by 2006, goes untaxed ).
24.
"The New York Times ", in discussing a trust that Rockefeller set up for his born and yet-to-be born great-grandchildren, stated that he " left a gross estate of $ 102, 000, 000 which was reduced to $ 50, 000, 000 principally by $ 30, 000, 000 of debts and $ 18, 600, 000 of inheritance and estate taxes ."
25.
At the death of Henrietta King, the appraiser's " Statement of Gross Estate, Mrs . H . M . King " listed a net total of $ 5.4 million, as the owner of 997, 444.56 acres ( 4, 036.5 km 2 ), which did not include the Santa Gertrudis headquarters, nor did it include the Kleberg's Stillman and Lasater tracts, which were not of the estate.
