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Old 01.02.2017, 16:46
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Inheritance Tax on US Assets for Non-Residents

There is some discussion going on in another broker related thread about US inheritance tax on non-residents for US situated assets (e.g. Google shares in a Swiss account etc.)

Few years back that I checked on this, I came across US-Switzerland Estate Tax Treaty (signed in 1950s), which gives Swiss domiciled persons same exemption limit as US citizens (currently approx USD 5.2 million). So for Swiss tax residents/domiciled unless they are more than USD 5 million invested in US-situated assets, US inheritance tax is not an issue.

Treaty document here:
https://www.eda.admin.ch/content/dam...en/tax1951.pdf

I thought it worthwhile to put this out there so people have some clarity and don't take redundant decisions which affect their investments. Happy to know if I have missed something.
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Old 01.02.2017, 17:05
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Re: Inheritance Tax on US Assets for Non-Residents

More to throw in the mix: https://www.amcham.ch/publications/d...ern_treaty.pdf
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Old 03.03.2017, 14:35
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Re: Inheritance Tax on US Assets for Non-Residents

Quote:
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There is some discussion going on in another broker related thread about US inheritance tax on non-residents for US situated assets (e.g. Google shares in a Swiss account etc.)

Few years back that I checked on this, I came across US-Switzerland Estate Tax Treaty (signed in 1950s), which gives Swiss domiciled persons same exemption limit as US citizens (currently approx USD 5.2 million). So for Swiss tax residents/domiciled unless they are more than USD 5 million invested in US-situated assets, US inheritance tax is not an issue.

Treaty document here:
https://www.eda.admin.ch/content/dam...en/tax1951.pdf

I thought it worthwhile to put this out there so people have some clarity and don't take redundant decisions which affect their investments. Happy to know if I have missed something.
I am afraid it is not quite that simple

Quote:
The Treaty allows to the estate of a Solely Swiss
Decedent a percentage of the exemption amount available
to U.S. citizens and domiciliaries, based upon the ratio of the
decedent’s U.S. situs assets to worldwide assets
. Thus, if a
Solely Swiss Decedent dies in 2011 having a worldwide estate
of US$ 50 million of which US$ 5 million consists of U.S.
situs assets (e.g., shares in U.S. corporations and U.S. real
estate), the estate would be allowed an exemption amount
of US$ 500,000 (10% of the exemption amount available to
U.S. persons). In this example, the remaining U.S. taxable
estate (e.g., US$ 4.5 million) would be subject to U.S. estate
tax at the rate of 35% (effective for 2010, 2011, and 2012).
I would phrase it like: if your ww assets are below 5 mil, you don't need to worry about US estate tax.
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Old 03.03.2017, 14:53
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Re: Inheritance Tax on US Assets for Non-Residents

AFAIK, shares in a foreign domiciled fund are not considered U.S. situs assets for U.S. estate tax, even if everything that the fund itself owns is.

Vanguard claims this here
https://www.google.ch/url?sa=t&sourc...o1IpXnU_wwQJ4w
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