Inheritance, estate & gift tax guides
Guides for 2026 — for a single country or across borders. Each ends in a free calculator that shows the statutory reason behind every figure, with treaty relief when more than one country is involved.
Single-country guides
Everything in one jurisdiction — the exemptions, rates, allowances and reliefs that decide a domestic estate, inheritance or gift.
US estate tax calculator →
The $15M federal exemption, 40% rate, portability, step-up in basis, and the 16 states + DC with their own death tax.
UK inheritance tax calculator →
The £325k nil-rate band, £175k residence band and taper, 40% rate, the 7-year gift rule and the 2026 relief cap.
France succession tax calculator →
Per-heir allowances, the direct-line scale to 45%, the spouse exemption, assurance-vie and the 15-year gift refresh.
Canada estate tax calculator →
No inheritance tax — but a deemed disposition taxes capital gains at death, with the spousal rollover and provincial probate.
Ireland inheritance tax calculator →
Capital Acquisitions Tax at 33%, the €400k Group A threshold, Groups B and C, and the key exemptions.
Germany inheritance tax calculator →
Erbschaftsteuer: the €500k spouse and €400k child allowances, tax classes I–III, and the 7–50% scale.
Spain inheritance tax calculator →
ISD: the state 7.65–34% scale, group allowances, and why Madrid/Andalusia can cut the bill ~99%.
Italy inheritance tax calculator →
Among Europe's lightest: a €1M allowance per close relative and rates of just 4% / 6% / 8%.
Netherlands inheritance tax calculator →
Erfbelasting: the €828k partner exemption, €26k child exemption, and the 10/20% and higher bands.
Japan inheritance tax calculator →
Sōzokuzei: the ¥30M + ¥6M-per-heir exclusion, the 10–55% scale, and the large spouse relief.
Cross-border guides
When a gift or inheritance touches two countries — who taxes what, how treaties relieve double taxation, and the traps that catch families.
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.