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The Cross-Border Wealth Playbook · Free Tool

Are you holding US shares the expensive way?

For a non-US investor, owning US-market exposure directly can quietly cost you twice — in dividend withholding every year, and in US estate-tax exposure on assets that are "US-situs" even when held abroad. The same exposure through a non-US-domiciled fund often cuts both. See the difference on your own numbers.

Your US-market exposure
$
%
Roughly what the holding pays out in dividends each year.
Dividend withholding rates
%
US default is 30%; a treaty often reduces it to 15%.
%
Often the treaty rate of the fund's domicile (e.g. 15%).
Estate exposure assumptions
$
%
Annual dividend withholding lost

Direct US shares

$0
withheld each year

Via non-US fund

$0
withheld each year
Difference, per year$0
Over 20 years (undiscounted)$0
US-situs estate exposure (non-US person)

Direct US shares

$0
US estate tax if you died holding this

Via non-US fund

$0
not US-situs
The avoidable cost
$0
Enter your numbers to see the difference.
The two mirror traps

The same investment, held two ways, is taxed two ways.

Where a fund is domiciled — not where you buy it or where you live — drives how a cross-border investor is taxed on it. For a non-US person, holding US shares or a US-domiciled fund directly can mean higher dividend withholding and exposure to US estate tax on "US-situs" assets above a low threshold, even when the assets sit in an account outside the US. The common, low-cost fix is to hold the same market exposure through a non-US-domiciled fund.

Trap one · withholding

Dividends from US holdings are taxed at source. Held directly, often at the full rate; through a well-chosen non-US fund, frequently at a lower treaty rate — a difference that compounds every year you hold.

Trap two · US-situs estate

US shares and US-domiciled funds count as US-situs for estate tax — payable by a non-US person on amounts above a low threshold, at high rates. A non-US-domiciled fund holding the same shares generally is not US-situs.

The full treatment is in The Cross-Border Wealth Playbook.

Chapters 14 and 15 — where to hold your investments and the US-situs estate trap — plus a ten-model companion workbook with this comparator built in. Get the investing chapters and the launch notice.

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Educational orientation only — not tax, legal, or investment advice, and not a substitute for a qualified cross-border (and, if relevant, US) adviser. Withholding rates depend on the specific treaty and fund domicile; the US-situs threshold, estate-tax rate, and situs rules vary and change, and an estate-tax treaty can alter them. The 20-year figure is undiscounted and ignores reinvestment. Confirm your own status and the current rules before acting. If you are a US person, the situs analysis differs — these traps mainly concern non-US persons.
Educational references and tools — not legal, tax, accounting, or investment advice, and not a recommendation to buy or sell any security. Consult a qualified professional about your specific situation. © 2026 The Baratelli Institute.