Question 1

How is cross-border inheritance tax calculated?

Accepted Answer

Each country taxes an estate or gift based on connecting factors — the deceased's or donor's domicile and nationality, the beneficiary's residence, and the situs (location) of each asset. Two countries can tax the same asset, in which case an estate- or inheritance-tax treaty or a unilateral foreign-tax credit usually relieves the double tax. HeirCalc computes the exposure in each of 21 fully modeled countries, applies treaty or unilateral relief per asset, and flags unresolved overlaps rather than silently netting them.

Question 2

Can I be liable for inheritance or estate tax in two countries at once?

Accepted Answer

Yes. When the deceased is domiciled in one country, the heir resides in another, and assets sit in a third, several jurisdictions can each assert a claim. Estate-tax treaties (the US has around 15; the EU has roughly 33 bilateral estate/inheritance treaties) allocate taxing rights and grant credits, but most country pairs have no treaty, leaving a real double-taxation risk that must be modeled asset by asset.

Question 3

What is 'situs' and why does it matter for estate tax?

Accepted Answer

Situs is the legal location of an asset. Many countries — including the United States for non-resident aliens — tax assets located within their borders regardless of where the owner lived. US-situs assets such as US real estate and shares of US corporations can expose a non-resident alien's estate to US estate tax above only a $60,000 exemption, so situs is often the single most important driver in a cross-border estate.

Question 4

Which countries have estate or inheritance tax treaties with the United States?

Accepted Answer

The United States has estate and/or gift tax treaties with roughly 15 countries, including the United Kingdom, France, Germany, Greece, the Netherlands, Italy, Denmark, Japan, and a handful of others. These treaties determine which country has primary taxing rights and how credits apply; for most of the world there is no US estate-tax treaty, and only a unilateral foreign-tax credit may be available.

Question 5

Does HeirCalc give tax advice?

Accepted Answer

No. HeirCalc produces an estimated tax exposure with the statutory drivers behind it, for discussion and planning. It is not legal, tax or financial advice, and results should be confirmed with a qualified cross-border tax professional before acting.