Domicile for Immigration and Federal Gift and Estate Tax Purposes--Is a Harmonious Rule Possible

This Article explores the question of when does a nonimmigrant alien establish a United States domicile and, thus, a residence subjecting him to estate and gift tax. The authors argue that the case law, in both the tax and immigration fields, gives only a partial answer to that question, and identifies only the G-4 visa holder as capable of establishing a domicile, but fail to include other categories. The authors recommend that regulations be promulgated to delineate whether and under what circumstances each category of nonimmigrant aliens may, if at all, establish a United States domicile.