XJuly 16, 2026
A US citizen shields 15 million dollars from federal estate tax.
A non-American who never lived in the US shields 60,000 dollars.
Above that line the same tax, climbing to 40 percent. Same Apple shares. A shield 250 times smaller.
This is US federal estate tax, and it turns on citizenship and domicile, not on how many days you spend there. A US citizen, or anyone domiciled in the US, is taxed on their worldwide estate with a 15 million dollar exemption in 2026. Someone who is neither is taxed only on US-situs assets, and the shelter collapses to 60,000 dollars. The first 60,000 are wiped by a credit. Above that the marginal rate opens at 26 percent and climbs to 40 once the taxable base tops 1 million dollars.
The trap is what counts as US-situs. US real estate, yes. But also stock of any US corporation, Apple, Nvidia, a direct position, even when it sits in a brokerage account in your own country. The situs follows the issuer, not where the shares are held.
A treaty can soften it, lifting the shelter or narrowing what is taxed. The US has estate tax treaties with only about 15 countries. UK, France, Germany and Japan are in. China, India, Brazil, Mexico and most of the world are not. No treaty, and you are back to the 60,000.
So it is not the US brokerage account that triggers this, it is holding US-situs assets directly. Shares in an Irish UCITS ETF, structured as an investment company or ICAV, are generally not US assets even when the fund holds only US stocks. Same S&P 500 exposure, a non-US wrapper, and the situs trap falls away. The custodian never mattered. The structure around the asset does.
The dividend withholding on US stocks gets priced to the basis point. The estate tax on the very same shares almost never gets a look.
Hold US stock directly, and you are neither a US citizen nor US-domiciled: do you know which side of 60,000 your heirs land on?
Data from GeoCompass, the jurisdiction intelligence layer I build at Lucky Nomads.
Brazil
China
France
Germany
India
Japan
Mexico
United Kingdom
United States