Antonio Nero, a citizen of Italy, has a U.S. Green Card and has resided in the U.S. for more than 20 years. Antonio has accumulated a substantial net worth of more than $50,000,000 but he has a large portion of his assets in U.S. tax-free bonds and thus has not minded paying whatever U.S. income tax he has had to pay. Antonio is a widower, he has used up his unified exemption, he is getting old      quickly and his health has deteriorated. Antonio wants to develop a plan to begin transferring substantial assets to his 4 U.S. citizen sons and in recent years he has started spending substantial time in Bermuda where he has met a wonderful woman who resides there. Antonio would be happy to move to Bermuda on a permanent basis. Antonio meets with you to discuss some planning steps. What would provide Antonio and his sons with the better U.S. Transfer Tax minimization opportunity?