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A “foreign estate” is Legal Tax Avoidance by Definition

(31) Foreign estate or trust

(A) Foreign estate

The term “foreign estate” means an estate the income of which, from sources without the United States which is not effectively connected with the conduct of a trade or business within the United States, is not includible in gross income under subtitle A.

[26 U.S.C. § 7701(a)(31)]

“without the United States” – 70x by SCOTUS between 1810-2002 to describe a lack of U.S. jurisdiction

“within the United States” – 886x by SCOTUS between 1788-2023 to affirm U.S. jurisdiction