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Archive for U.S. Interactive Tax Treaties Map

IRS States Some Nonresidents With U.S. Assets Must File Estate Tax Returns

Some Nonresidents with U.S. Assets Must File Estate Tax Returns

Certain deceased nonresidents who were not citizens of the United States are subject to U.S. estate taxation with respect to their U.S.-situated assets. For estate tax purposes, a citizen of a U.S. possession is not a U.S. citizen.

U.S.-situated assets that are subject to estate tax include, for example:

  • Real estate located in the U.S.,
  • Tangible personal property (excluding some art), and
  • Stock of corporations organized in or under U.S. law, even if the nonresident held the certificates abroad or registered the certificates in the name of a nominee.

Examples of property treated as situated outside the U.S., and therefore not subject to the U.S. estate tax, include certain deposits and debt obligations described in Section 871(g)-(i), bank accounts deposited with a foreign branch of a domestic commercial banking business, and proceeds of life insurance on the life of a nonresident who is not a U.S. citizen.

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