Andrea, a citizen and resident of Peru, is contemplating investing in an apartment building in Miami. Should US estate taxes affect the manner in which the investment is structured? Consider the following alternatives:

(a) Andrea owns the apartment building individually.

(b) She owns the apartment building in a limited partnership that owns the apartment building. See Rev. Rul. 55-701.

(c) She owns stock of a Florida corporation that owns the building.

(d) She owns stock of a Panamanian corporation that owns the building.