Updated 2026-09-27 · US · General education

Start with an asset inventory

A US company share, a fund investing in the US and a non-US account are different layers. Record exactly what is owned before drawing conclusions from the broker’s address or a dollar valuation.

An asset can have US estate-tax connections even when its owner lives elsewhere.

US situs exposure

Estate-planning questions for some non-US investors

01. Assets to review

US company shares; funds, checking domicile; US property; other US-situs assets.

02. Why it can matter

Estate exposure; heir administration; cross-border documents; ownership structure.

03. Questions to ask

What do I hold directly? Who inherits? Does the structure fit? Is my family prepared?

Consider the assets, then their ownership and structure, then heirs and administration.

Assets, ownership and structure, heirs and administration

Review the full estate-planning picture.

US-incorporated shares can be US-situated regardless of where they are held. Treaties, ownership and the nature of the asset need a separate review.View full size

Residence and asset location are different questions

A person can live outside the United States and still directly own an asset treated as situated in the United States for estate-tax purposes. This is why the legal nature and location of the asset matter.

  • Direct shares in US corporations can be important.
  • US real property can be relevant.
  • Employee equity can become relevant once it converts into directly owned shares.

Do not reduce the analysis to one threshold

The widely discussed filing threshold is not the same thing as a simple tax-free allowance or a flat tax calculation. Treaties, deductions, ownership and the wider estate can all affect the analysis.

  • Identify whether a treaty may apply.
  • Map direct US-situated holdings.
  • Review ownership through brokers, nominees and wrappers rather than assuming the platform location decides situs.

Structures need legal and tax analysis

An international account or wrapper does not automatically remove US-situs exposure. The key question is what the investor legally owns and how the structure is treated in the relevant jurisdictions.

Connect ownership with the wider family plan

Sources and scope

US nonresident/noncitizen estate concepts; IRS source checkpoint 25 September 2026. Estate-tax residence, treaties, ownership and filing facts require separate review.

General information; does not establish individual eligibility, tax treatment or suitability.

For information and guidance only. Results are illustrative, based on your assumptions, and are not personalised financial advice. Methodology & limitations