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Hi and welcome to Just Answer!Deceased nonresidents who were not American citizens are subject to U.S. estate taxation with respect to their U.S.-situated assets. U.S.-situated assets include American real estate, tangible personal property, and securities of U.S. companies.
Executors for nonresidents must file an estate tax return ( Form 706NA, United States Estate (and Generation-Skipping) Tax Return, Estate of a nonresident not a citizen of the United States) if the fair market value at death of the decedent's U.S.-situated assets exceeds $60,000 ($60,000 is the "exemption equivalent" of the applicable unified credit of $13,000).
Thank you for helping. I understand those basic principles. I need to know whether that result is changed under the specific terms of the US-UK Estate and Gift Tax Treaty.
There is no separate tax treaty for Estate and Gift taxes.
The UK-US estate and gift tax convention provides an election to use the larger exemption available to US residents (i.e., $5,000,000 million instead of $60,000 for decedents died in 2011) provided the worldwide estate are included in calculation of US estate tax.Here is a document - http://uniset.ca/misc/us-uk1980.html