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The Cross-Border Wealth Playbook →
The Cross-Border Wealth Playbook · Free Tool

Could the US tax your estate?

You don't have to be American, or ever have lived in the US, to owe US estate tax. US shares, US funds, and US real estate are "US-situs" assets — taxed by the US on a non-resident's death above a strikingly low threshold, at rates near 40%. Most people have never heard of it. See your exposure, and how much of it a non-US-domiciled fund can remove.

First, are you a US person?
This estimator is for non-US persons — the case where the US-situs trap bites hardest.
Your US-situs assets (held directly)
$
$
$
US-located property is US-situs even held through some structures — confirm.
$
e.g. tangible property located in the US.
Assumptions (confirm current)
$
%
Estimated US estate tax exposure
$0
on your US-situs assets, if you died holding them directly
Total US-situs assets$0
Less non-domiciliary threshold$0
Taxable US-situs estate$0
The fix (Chapter 15)
$0 of exposure removed
Holding the same US-market exposure through a non-US-domiciled fund generally makes it not US-situs — removing the estate exposure while keeping the investment.
The hidden estate tax

A tax you can owe in a country you've never lived in.

The US taxes the estates of non-US persons on their "US-situs" assets — and the threshold above which it applies to a non-domiciliary is strikingly low (long set around $60,000), far below the large exemption US citizens enjoy. US shares and US-domiciled funds count as US-situs even when held in an account outside the US; so does US real estate. The rate climbs toward 40%. It is one of the most common, most expensive surprises in cross-border wealth — and one of the most avoidable.

What counts as US-situs

US company shares (even held abroad), US-domiciled funds/ETFs, US real estate, and US-located tangible property. US bank deposits often do not — but confirm, the rules are technical.

The common fix

Hold US-market exposure through a non-US-domiciled fund rather than US shares or US funds directly. Same investment exposure; generally not US-situs — so the estate exposure falls away. A non-citizen surviving spouse raises a separate issue (QDOT).

This is Chapter 15 of The Cross-Border Wealth Playbook.

The US-situs estate trap, seen from both sides — the family moving wealth into the US and the non-resident who simply holds US assets — plus the fixes, the QDOT spousal issue, and a companion workbook that maps your whole estate by situs. Get the chapter and the launch notice.

The US-situs chapter + launch notice. No spam; unsubscribe anytime.
Educational orientation only — not tax, legal, or estate-planning advice, and not a substitute for a qualified cross-border (and US) adviser. This is a simplified estimate: it ignores deductions, debts, treaty relief (an estate-tax treaty can raise the threshold or change situs), the marital/QDOT rules, valuation nuance, and the very different treatment of US persons (who are taxed on their worldwide estate but enjoy a large exemption). Situs rules are technical and asset-specific, and the threshold and rate change. Confirm your own status and the current figures before acting.
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.