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RD, Certified Public Accountant (CPA)
Category: Tax
Satisfied Customers: 8784
Experience:  CPA, MBA, Over 10 yrs of experience in tax planning and business consulting..
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Are non US citizens not residing in the US subject to inheritance

Customer Question

Are non US citizens not residing in the US subject to inheritance tax on US securities holdings even if they are held outside the US?
Submitted: 6 years ago.
Category: Tax
Expert:  RD replied 6 years ago.
Is the deceased person, a resident of US? What State was the decedent a resident of?
Customer: replied 6 years ago.
The deceased person is not a resident of US nor a US citizen
Expert:  RD replied 6 years ago.

Yes, the securities holding in US Domestic Corp will be subject to estate tax.



A non-resident alien is subject to U.S. estate tax on their

taxable estate assets situated in the U.S. (IRC §2101(a), 2106(a)).

For U.S. estate tax, both stock of a U.S. corporation (IRC

§2104) and U.S. real estate (Treas Reg §20.2104-1(a)91)) are

"situated" in the U.S.


See link to Sec 2104


and IRS link for your reference-,,id=156329,00.html



Let me know if you have any question.


Please note: This advice is provided with the understanding that all the relevant facts have been provided by you. Any change in facts might affect the advice given and hence may not be relied on in such cases. Nothing contained in this reply was intended or written to be used, can be used by any taxpayer, or may be relied upon or used by any taxpayer for the purposes of avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code of 1986, as amended.