@BobKammanWhat follows that was "because there are still complicated gift and estate tax considerations."  That's where common sense often fails - they know what they know but don't know what they don't know.  An advisor's job is to help clients understand their options as well as the pros and cons of each, so that clients can make an informed decision - but never to make a decision for a client.  As for marriages with foreign nationals, we can trade stories of many varieties as with everything else in life but don't think there's enough time, lol.