Husband and Wife married in China. Together they created a successful company in Singapore. They have one child. Wife and child live in Pasadena, California. Wife has a job at Cal Tech.

Husband purchased a home in his name in China where he maintains his Chinese citizenship and is a tax resident. Husband also set up an investment account in Singapore. All the assets in Husband's name were acquired during the marriage from both Husband and Wife's efforts.

Wife bought a home in her name and set up an investment account in California. Those assets were acquired during marriage and the assets were from both Husband and Wife's efforts.

The assets in Husband's name are valued at $50 million. The assets in Wife's name are valued at $15 million. Husband earns $500,000 each year as a salary from the Singapore company. Wife does not earn a salary from the company but does receive a modest salary from Cal Tech. However, Husband receives a dividend of $500,000 paid out each year.

1. Is there any action Husband and Wife should have taken before Wife and child moved to the United States?
2. What information do we need to know in order to help Husband and Wife from an estate planning point of view?
3. If all income earned by the couple would generally have been considered community property, does Wife have to include of Husband's salary as income in the U.S.? Does she have to include of the dividend? What about income and gains on the Singapore investment account? (Please read Section 879 to answer this question.)
4. Also, please discuss Section 6013 as discussed in Section 879...why would Husband ever make this election?)