Step up basis for securities owned in a US brokerage by non-US residents

[ptax255]

Hello,

Does step up basis apply in this case? Beneficiary is a US person in CA. Parents are non US residents with a brokerage in the US. 

[sjrcpa]

Who died?

[IRonMaN]

Are you sure he died --------- I thought who's on first. 😉

[ptax255]

The father (foreign resident with US brokerage)

[IRonMaN]

I do not dabble with any foreign clients but I believe they would still get the step up in basis.

[BobKamman]

Where is CA?  Canada or California? Or maybe Central America.   In any case, Rev. Rul. 84-139 says real estate gets stepped-up basis.  Same logic (although there's little to be found in its reading of Section 1014) would apply to personal property.