The United States has experienced a surge in immigration since 1970, and there are now approximately 45 million foreign-born people living in the United States. Some of them have become U.S. citizens, but many non-citizens live in the United States as well. In 2019 alone, approximately 1,031,000 foreign nationals obtained lawful permanent resident status. It is not only permissible, but essential for those individuals, like U.S. citizens, to have estate plans in place. There are a number of special issues non-citizens may need to consider.