US estate tax (non-resident)

US estate tax (non-resident) — when a non-US person dies holding US-situs assets above a $60,000 exemption, the excess faces US estate tax of 18–40%, gated by an IRS filing (Form 706-NA) that brokers wait on before releasing anything to heirs. A $300k US-fund position can cost heirs ~$70–90k plus months of friction. Ireland-domiciled UCITS funds sit entirely outside this regime — the single strongest argument for choosing structure on day one.

First used in: 1.6 · Cross-border plumbing