U.S. Estate Tax Calculator for Non-Residents

Yes. U.S. real estate is taxable where it sits, and no treaty removes that. If you are not a U.S. citizen or domiciliary, your U.S. situs assets are exposed to federal estate tax on death at rates rising to 40%. It applies to the value of the asset rather than to any profit, so a property that has never made money is still fully within scope.

Sixty thousand dollars. A U.S. citizen or domiciliary has an exemption of $15 million for 2026, so the gap is enormous. Everything above $60,000 is taxed on a rising scale that reaches 40%, which means a single mid-priced rental held personally can create a six figure liability.

U.S. real estate always counts, as do shares in U.S. companies and U.S. domiciled exchange traded funds, wherever the certificates are held. Foreign bank accounts, non-U.S. funds, and most cash held outside the country do not. Investors are frequently caught out by U.S. shares sitting in a brokerage account rather than by the property itself.

A single-member LLC does not, because it is disregarded for tax purposes and the IRS looks straight through it to the property underneath. Structures that genuinely change the situs of the asset do exist, but they carry their own income tax cost, they have to be in place before death rather than after, and they need proper cross-border advice.

A small group, including Canada, the United Kingdom, Germany, France, the Netherlands, Austria, Denmark, Australia, Finland, Greece, Ireland, Italy, Japan, South Africa, and Switzerland. Brazil, Spain, Taiwan, Colombia, Mexico, India, the UAE, Singapore, and most other countries have none. The modern treaties scale the exemption by the share of your worldwide wealth sitting in the U.S., while the older situs based treaties work differently.

It depends entirely on the type of loan. A non-recourse mortgage, where the lender can only take the property itself, reduces the taxable U.S. value in full. A recourse mortgage is only deductible in proportion to your U.S. assets measured against your entire worldwide estate, which is often a small fraction. That single distinction can move the bill by tens of thousands of dollars.

Form 706-NA is the United States estate tax return for the estate of a non-resident who was not a citizen. It has to be filed once U.S. situs assets exceed $60,000, whether or not any tax is actually payable, and it falls due nine months after the date of death. An extension of time to file can be requested, but that does not extend the time to pay.

Penalties and interest accrue from the original due date rather than from the point the IRS notices. Beyond that, your heirs can be left without a proper record of the cost basis, which means a second tax bill later when they come to sell. Filing is also what allows any treaty relief to be claimed in the first place.

They are often used interchangeably, but they are not the same and the wording matters. The U.S. has no federal inheritance tax. The federal tax on death is estate tax, paid by the estate before assets pass to heirs, and it is what applies to a foreign owner's U.S. assets. A handful of U.S. states levy their own inheritance tax separately. So if you are searching for US inheritance tax as a non-resident, the estate tax on this page is what you are looking for.

Yes, and this is the trap that catches people who were only worried about their property. Shares in U.S. companies and U.S. domiciled ETFs are U.S. situs assets for estate tax wherever the account is held, so they count toward the $60,000 threshold just like real estate. Non-U.S. funds, for example many Irish domiciled UCITS ETFs, are generally not U.S. situs, which is why fund domicile is a common planning point for internationally mobile investors.

There are several levers, but all of them have to be in place before death. Financing with non-recourse debt reduces the taxable U.S. value dollar for dollar. A treaty, if your country has one, can enlarge the $60,000 exemption. Holding structures such as a foreign corporation can change the situs of the asset. Life insurance can fund the eventual bill. Each carries income tax or cost trade-offs, so this is a plan ahead decision needing cross-border advice rather than a form you file at the end. A single-member LLC on its own does not help.

Yes. Canada has no estate tax of its own, but U.S. real estate owned by a Canadian is fully within the U.S. estate tax charge above $60,000. The Canada and U.S. treaty helps, because it gives Canadians a pro-rated share of the larger U.S. exemption based on the U.S. portion of their worldwide estate, which can significantly reduce or eliminate the tax for smaller estates. Canada's own deemed disposition, meaning capital gains at death, is separate, and Form 706-NA may still be required.

A UK resident who owns U.S. property faces the same $60,000 exemption and rates up to 40%, but the U.S. and UK estate and gift tax treaty provides meaningful relief, broadly allowing a domicile based approach that can give access to a much larger exemption. It is separate from UK inheritance tax, which may also apply to your worldwide estate, with treaty relief preventing the same asset being taxed twice. Given recent changes to the UK non-dom rules, this is worth reviewing with a cross-border adviser.

Be careful, because U.S. gift tax rules for non-residents are different from the estate tax rules. Gifts of U.S. real estate and other tangible U.S. property are subject to U.S. gift tax, with only a modest annual exclusion, so simply giving the property away usually creates a gift tax problem instead. Gifts of U.S. shares, by contrast, are not subject to U.S. gift tax, which is one reason share holdings are treated differently in planning. Lifetime transfers can be part of a strategy, but only a properly advised one.

Yes, and estate tax is a planning issue rather than a reason to stay out. There is no restriction on foreign nationals owning U.S. rental property, and financing is available through DSCR loans that qualify on the rental income rather than your personal income or U.S. credit history. What matters is understanding the exposure and dealing with it while you are alive. Our purchase support service helps overseas investors buy and structure remotely.