USA: Estate Tax treaties

USA: Estate Tax treaties

The U.S. is a signatory to several important estate, gift, and generation-skipping transfer tax treaties. The article gives a short introduction to the requirements and the benefits of the existing treaties.

Tax treaties with respect to estate, gift and generation-skipping tax are currently in force with 19 countries. However, not every treaty covers estate, gift and generation-skipping tax (see attached table).

The tax treaties generally apply to Estates of deceased persons whose domicile at their death was in one or both of the Contracting States, and Gifts of donors whose domicile at the making of a gift was in one or both of the Contracting States. Double taxation is either avoided by defining the fiscal domicile (see Art. 4 of the German-US estate and inheritance treaty), limiting the right of situs taxation (see Art. 8 German-US estate and inheritance treaty) or allowing for relief against the taxes paid in the other jurisdiction (e.g. Switzerland).

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