US estate tax calculator for nonresidents 2026

In short

The United States taxes a non-resident who is not a US citizen only on assets situated in the United States, such as US real estate and shares of US companies, above 60 000 dollars, at 18 to 40 per cent (IRC 2101, 2102(b)(1) and 2001(c)). A treaty such as the Swiss convention of 9 July 1951 can widen the exemption, and a surviving spouse who is not a US citizen gets no marital deduction unless the assets pass to a qualified domestic trust (IRC 2056(d)).

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Law as read on 12 October 2026.

Non-residents: the answer in three lines

If you are neither a US citizen nor domiciled in the United States, US estate tax reaches only your US-situated assets, such as US real estate and shares of US companies.
The estate must file Form 706-NA once those assets exceed 60 000 dollars; tax runs from 18 to 40 per cent, against a credit of 13 000 dollars instead of the 15 000 000 dollar exclusion a US citizen or resident has in 2026.
A surviving spouse who is not a US citizen gets no marital deduction unless the assets pass to a qualified domestic trust, and an estate tax treaty can widen the exemption.

	US citizen or resident	Non-resident, not a citizen	Basis
Exemption or threshold	Basic exclusion of 15 000 000 dollars for deaths in 2026.	Credit of 13 000 dollars, sheltering about 60 000 dollars of US-situated assets; return required above 60 000 dollars.	IRS, Estate tax; IRC 2102(b)(1); IRS, Some nonresidents with US assets must file
Rates	18 to 40 per cent, top rate above 1 000 000 dollars.	Same schedule, 18 to 40 per cent.	IRC 2001(c); Form 706 instructions, Table A
Situs or scope	Worldwide assets; a US citizen is taxed worldwide wherever they live.	US-situated assets only: US real estate, tangible property in the US, shares of US corporations. Life insurance on the deceased's life is not a US asset.	IRS, Some nonresidents with US assets must file; IRC 2103, 2104, 2105
Spouse	Assets passing to a US citizen spouse may be deductible; unused exclusion can pass to the surviving spouse.	No marital deduction for a non-citizen spouse unless the assets pass to a qualified domestic trust (QDOT).	IRC 2056(d), 2056A; IRS, Estate tax; IRS FAQ, nonresidents
Treaty relief	Not usually relevant for the US estate of a citizen.	Estate or gift tax treaties with 15 countries, including Switzerland, the United Kingdom, France, Germany, Japan and Australia; a treaty can pro-rate the full credit. Claim on Schedule B with Form 8833.	IRS, Estate and gift tax treaties; IRC 2102(b)(3)(A); IRS FAQ, nonresidents
Filing form	Form 706.	Form 706-NA, due 9 months after death.	IRS, Some nonresidents with US assets must file; Instructions for Form 706-NA

Compare countries: Inheritance tax for non-residents, by country, 2026

Law as read on 14 October 2026; the 2026 exclusion and the 60 000 dollar filing threshold re-read on IRS pages on 19 October 2026. Educational only, not personal advice.

Key figures

A nonresident who is not a US citizen is taxed only on assets situated in the United States.
The threshold is 60 000 dollars of US-situated assets, and it is not indexed for inflation.
The unified credit for such an estate is 13 000 dollars under IRC 2102(b)(1), which shelters exactly that first 60 000 dollars.
The rate schedule of IRC 2001(c) runs from 18 to 40 per cent, and the top rate applies above 1 000 000 dollars of taxable estate.
Shares of a US corporation are US-situated wherever the account and the broker are. Deposits in a US bank not connected with a US business are not.
The dividing line is domicile, not residence and not immigration status.
A treaty, including the Swiss convention of 9 July 1951, can replace the 13 000 dollar credit by a credit prorated on the US share of the worldwide estate, under IRC 2102(b)(3)(A).
Form 706-NA is due within nine months of death, and US custodians generally require the IRS transfer certificate before releasing the assets.

For non-residents

Scope: assets situated in the United States only, including US real estate and shares of US corporations, even when the certificates are held abroad (IRC 2103; IRS, Some nonresidents with U.S. assets must file estate tax returns).
Threshold: a return is required above 60 000 dollars of US-situated assets, the amount the 13 000 dollar credit shelters (IRC 6018(a)(2) and 2102(b)(1)).
Rates: 18 to 40 per cent, the top rate applying above 1 000 000 dollars (IRC 2001(c)).
Spouse: no marital deduction for a surviving spouse who is not a US citizen, unless the assets pass to a qualified domestic trust (IRC 2056(d)).
Filing: Form 706-NA, within nine months of death (IRC 6075(a)).

Law as read on 12 October 2026.

US estate tax simulator, nonresident decedent

An estimate of the federal estate tax on assets situated in the United States. It assumes the deceased was not a US citizen and was not domiciled in the United States.

Year of death

US-situated assets (USD)

Country of domicile with a death tax treaty

Debts and administration expenses (USD)

Adjusted taxable gifts of US property (USD)

Surviving spouse

Value passing to the surviving spouse (USD)

The surviving spouse is a US citizenA qualified domestic trust is in place, IRC 2056A

The deceased was a US citizen or domiciled in the United States

Taxable estate1,000,000 USD

Tentative tax, IRC 2001(c)345,800 USD

Unified credit (statutory, IRC 2102(b)(1))13,000 USD

Estate tax due332,800 USD

Marginal rate40 %

Effective rate on US assets33.28 %

Form 706-NA must be filed, within nine months of death.

Points to note

Form 706-NA is due within nine months of death. Form 4768 gives a six-month extension to file.
US custodians and transfer agents generally require the IRS transfer certificate before releasing the assets, and it follows the return.

Sources

Check the result against the guidance it comes from:

Direct holdings only. Assets held through a company, a trust or a partnership follow separate rules that this tool does not model, and those structures are often the reason the exposure is not what it appears.

Nothing you enter is stored, sent or logged. The whole calculation runs in your browser.

Worked examples

Three typical cases, worked out with this calculator's own rules. Reliefs it does not model are left out.

Case	Assumptions	Result	Legal basis
Non-resident holding US sharesComputed by this calculator	AssumptionsDeceased neither a US citizen nor domiciled in the United States, no treaty; shares of US companies worth 1,000,000 USD; no deductions; death in 2026.	ResultTax 332,800 USD, 33.28% of the US assets, after the 13,000 USD credit.	Legal basisIRC 2001(c), 2102(b)(1), 2103
Spouse who is not a US citizenComputed by this calculator	AssumptionsNon-resident, no treaty; US real estate worth 3,000,000 USD left entirely to a spouse who is not a US citizen; no qualified domestic trust.	ResultTax 1,132,800 USD: no marital deduction is allowed.	Legal basisIRC 2056(d), 2001(c), 2102(b)(1)
Domiciled in Switzerland, treaty creditComputed by this calculator	AssumptionsDeceased domiciled in Switzerland; US assets of 3,000,000 USD in a worldwide estate of 30,000,000 USD; no deductions.	ResultTax 551,220 USD: the credit becomes 594,580 USD, prorated on the US share of the estate.	Legal basisIRC 2102(b)(3)(A); US-Switzerland convention of 9 July 1951

The line is domicile, not residence

A decedent is a nonresident not a citizen if, at death, he was neither a US citizen nor domiciled in the United States. Domicile is acquired, in the words of the regulation, by living in a place, even briefly, with no definite present intention of later moving. It is not the green card test, not the substantial presence test used for income tax, and not where the tax returns were filed.

That is why the analysis cannot be lifted from an income tax file. A person can be a nonresident for income tax and a domiciliary for estate tax, and the second is what decides the exposure here.

What is taxed and what is not

Only assets situated in the United States are within the charge. The category is narrower than most holders assume, and it cuts in unexpected places.

Taxed: US real property, tangible property physically in the United States, and shares of US corporations, however and wherever they are held.
Not taxed: deposits in a US bank account not connected with a US business, and proceeds of life insurance on the life of the nonresident.
The trap: shares of a US corporation are US-situs even when held through a foreign broker, in a foreign account, by a person who has never set foot in the country. A holding in a US-domiciled exchange traded fund is inside the charge. The equivalent fund domiciled in Ireland or Luxembourg is not.

Sixty thousand dollars, and the cliff behind it

The unified credit for such an estate is 13 000 dollars under IRC 2102(b)(1), which shelters exactly the first 60 000 dollars of taxable estate. The IRS states that the filing threshold of 60 000 dollars is not indexed for inflation, and it has not moved in decades.

The rate schedule of IRC 2001(c) runs from 18 to 40 per cent, but the top rate applies above one million dollars of taxable estate, so anything of size is taxed at or close to forty. A million dollars of US shares held directly, with no treaty and no deductions, produces a tentative tax of 345 800 dollars and a liability of 332 800 after the credit.

The treaty changes the arithmetic, not the exposure

IRC 2102(b)(3)(A) allows an estate to claim, where a death tax treaty so provides, a unified credit prorated by the share of the worldwide gross estate situated in the United States, in place of the flat 13 000 dollars. Switzerland is among the countries whose treaty carries such a provision. The convention was signed on 9 July 1951 and entered into force on 17 September 1952.

The effect is decisive. Take the same million dollars of US shares, held by a person domiciled in Switzerland whose worldwide estate is ten million. The pro rata credit is a tenth of the applicable credit amount, and on 2026 figures that wipes out the liability entirely. Claiming it means filing, and disclosing the worldwide estate to the IRS, which is a decision in itself for a family that has never filed anything in the United States.

The treaty is of its period and is widely described by practitioners as obsolete. It is nonetheless in force, and the credit it opens is the single largest variable in the calculation.

A surviving spouse who is not American gets no marital deduction

The unlimited marital deduction that would shelter a transfer to a spouse is denied by IRC 2056(d) where the surviving spouse is not a US citizen. Property passing to a non-citizen spouse is taxed like any other, unless it passes through a qualified domestic trust under IRC 2056A.

For a couple who are both foreign nationals, with a joint brokerage account holding US shares, this means the first death is a taxable event on the deceased's share, and the survivor discovers the QDOT question at the worst moment to be learning it.

Filing, and the certificate that unlocks the assets

Form 706-NA is due where the US-situs assets, together with the gift tax specific exemption and adjusted taxable gifts, exceed 60 000 dollars. The deadline is nine months from death, with a six-month extension available on Form 4768.

The practical obstacle comes afterwards. The IRS issues a transfer certificate once the tax has been discharged or provided for, and US transfer agents, title companies and custodians generally will not release the assets without it. The certificate is not required for property administered by an executor appointed and acting within the United States. Estates should expect the process to run long: the heirs cannot reach the assets in the meantime.

Federal estate tax rate schedule, IRC 2001(c)
Taxable slice	Rate
Up to 10,000 USD	18 %
From 10,000 up to 20,000 USD	20 %
From 20,000 up to 40,000 USD	22 %
From 40,000 up to 60,000 USD	24 %
From 60,000 up to 80,000 USD	26 %
From 80,000 up to 100,000 USD	28 %
From 100,000 up to 150,000 USD	30 %
From 150,000 up to 250,000 USD	32 %
From 250,000 up to 500,000 USD	34 %
From 500,000 up to 750,000 USD	37 %
From 750,000 up to 1,000,000 USD	39 %
Above 1,000,000 USD	40 %

26 U.S.C. 2001(c). Threshold: 60,000 USD, unified credit 13,000 USD, IRC 2102(b)(1).

Questions

› Do non-residents pay estate tax in the United States?

› I have never lived in the United States. Am I exposed?

Yes, if you hold US-situs assets. Shares of US corporations are US-situs wherever the account is and whoever the broker is. Nationality and residence do not remove the charge; they only determine whether a treaty helps.

› Does a US-domiciled ETF count?

A fund organised as a US corporation is US-situs to that extent. The same strategy in a fund domiciled in Ireland or Luxembourg generally is not. For a non-US investor holding US equities, the fund's domicile is often the whole difference.

› What about my US bank account?

Deposits in a US bank not connected with a US trade or business are outside the estate tax charge, as are proceeds of life insurance on the life of the nonresident. Cash in a brokerage account is not the same thing as a bank deposit, and the distinction matters.

› I am domiciled in Switzerland. What does the 1951 treaty give me?

It opens the pro rata unified credit of IRC 2102(b)(3)(A): the applicable credit amount for the year of death, multiplied by the share of your worldwide estate situated in the United States, instead of the flat 13 000 dollars. Where US assets are a small part of a substantial estate, that often removes the liability. It requires filing and disclosing the worldwide estate.

› Can I leave my US assets to my spouse tax free?

Only if the surviving spouse is a US citizen, or the property passes through a qualified domestic trust. IRC 2056(d) denies the marital deduction to a non-citizen spouse otherwise.

› What happens if nothing is filed?

The assets stay where they are. Transfer agents and custodians generally require the IRS transfer certificate before releasing US securities or real estate to heirs, and that certificate follows the return. Doing nothing does not make the exposure go away, it makes the assets unreachable.

› Is this the same tax a US citizen pays?

The same rate schedule, a wholly different exclusion. A citizen or domiciliary is taxed on worldwide assets against a basic exclusion of a different order; a nonresident is taxed only on US assets against 60 000 dollars. The threshold for a nonresident is not indexed and the gap widens every year.

› What is the estate tax exemption for nonresident aliens?

Sixty thousand dollars of US-situated assets, sheltered by the unified credit of 13 000 dollars under IRC 2102(b)(1). It is not indexed for inflation. The far larger basic exclusion available to a citizen or domiciliary does not apply.

› What are US situs assets?

US real property, tangible property physically in the United States, and shares of US corporations however they are held. Deposits in a US bank not connected with a US trade or business are not, nor are the proceeds of life insurance on the life of the nonresident.

› What is the filing threshold for Form 706-NA?

Sixty thousand dollars, measured on the gross value of US-situated assets plus the gift tax specific exemption and adjusted taxable gifts. The return is due within nine months of death, with a six-month extension available on Form 4768.

› Are US stocks subject to estate tax for nonresidents?

Yes. Shares of a US corporation are US-situated wherever the account is held and whoever the broker is. A fund organised as a US corporation is caught to that extent; the equivalent fund domiciled in Ireland or Luxembourg generally is not.

Sources

IRS published guidance, the Form 706-NA instructions, and Rev. Proc. 2025-32 for the 2026 basic exclusion amount behind the treaty pro rata credit.

Internal Revenue Service

This page is educational and does not constitute legal or tax advice. Nothing you enter is stored, transmitted or logged; the whole calculation runs in your browser. Amounts are in US dollars, with no currency conversion.

Compare countries: Inheritance tax for non-residents, by country, 2026