How patient is the recipient? Either they are willing to wait, for possibly longer than their life, or they have to leave the US to access that money and not return to the US with that money.
If those are unacceptable and they have no wealth, because it’s locked up overseas, they could bring it all back for taxation minus 10 million.
If those are unacceptable and they have no wealth, because it’s locked up overseas, they could bring it all back for taxation minus 10 million.