Cross-border inheritance & estate tax guides
Country-pair guides for 2026 — who taxes a cross-border gift or inheritance, how treaties relieve double taxation, and the traps that catch families. Each ends in a free calculator that models both sides together.
US–UK cross-border inheritance & estate tax →
The $15M US exemption meets the UK's new residence-based IHT and the 1979 treaty.
US–Canada cross-border inheritance & estate tax →
US estate tax vs. Canada's deemed-disposition capital gains at death, coordinated by treaty.
US–France cross-border inheritance & estate tax →
US worldwide reach vs. French droits de succession, with the US–France treaty exemption.
US–Germany cross-border inheritance & estate tax →
US exemption vs. Germany's per-heir Erbschaftsteuer classes; treaty covers gifts.
US–Ireland cross-border inheritance & estate tax →
US estate tax vs. Irish CAT at 33% on the beneficiary; 1951 estate treaty.
US–Spain cross-border inheritance & estate tax →
US rules vs. Spain's region-driven ISD — and there is no US–Spain estate treaty.
US–Italy cross-border inheritance & estate tax →
US exemption vs. Italy's mild 4–8% succession tax; 1956 estate treaty.
US–Netherlands cross-border inheritance & estate tax →
US situs vs. Dutch residence-only rule; 1971 estate treaty.
US–Japan cross-border inheritance & estate tax →
US domicile reach vs. Japan's heir-residence tax; treaty covers gifts.
UK–France cross-border inheritance & estate tax →
UK residence-based IHT vs. French succession tax; 1963 estate convention.
UK–Spain cross-border inheritance & estate tax →
UK IHT vs. Spain's regional ISD — no UK–Spain treaty, so plan for double tax.
UK–Ireland cross-border inheritance & estate tax →
UK IHT vs. Irish CAT; the 1978 convention prevents double taxation.
General information for 2026, not legal, tax, or financial advice. Confirm your situation with a qualified cross-border professional. HeirCalc is an estimator by Krometis Analytics.