Treaty Countries and the Rest
The country of the decedent’s domicile, of the heir’s residence or of the payee decides which convention applies. The United States has estate tax conventions with fourteen countries; Article XXIX B of the income tax convention with Canada adds a fifteenth.
Law stated as of October 2026
Estate and gift tax conventions of the United States
| Country | Estate tax convention | Type | Gifts covered | Where the material is |
|---|---|---|---|---|
| Australia | May 14, 1953 | Situs | Yes | This website |
| Austria | June 21, 1982 | Domicile | Yes | This website |
| Canada | Income tax convention, Art. XXIX B (Protocol of March 17, 1995) | Credit and marital rules | No | This website |
| Denmark | April 27, 1983 | Domicile | Yes | This website |
| Finland | March 3, 1952 | Situs | No | This website |
| France | November 24, 1978; Protocol of December 8, 2004 | Domicile | Yes | FranceUSAlawtaxfinance.com, patrimoine-americain.com |
| Germany | December 3, 1980; Protocol of December 14, 1998 | Domicile | Yes | GermanyUSAlawtaxfinance.com, Vermoegen-USA.com |
| Greece | February 20, 1950 | Situs | No | This website |
| Ireland | September 13, 1949 | Situs | No | This website |
| Italy | March 30, 1955 | Situs | No | This website |
| Japan | April 16, 1954 | Situs | Yes | This website |
| Netherlands | July 15, 1969 | Domicile | No | This website |
| South Africa | April 10, 1947 | Situs | No | This website |
| Switzerland | July 9, 1951 | Situs | No | This website |
| United Kingdom | October 19, 1978 | Domicile | Yes | This website |
The convention with Sweden ended on January 1, 2008. Belgium, Spain, Luxembourg, Portugal, Monaco and Israel, among others, have no estate tax convention with the United States.
Two kinds of convention, and none
Six conventions, 1969 to 1983
Patterned on the OECD model. The country of domicile taxes the worldwide estate; the other country may in general tax only real property and business property situated there.
Eight conventions, 1947 to 1955
Each country keeps its statutory taxing right and its own situs rules; the convention adds a proportional exemption or credit and relieves the overlap.
The statutory regime
The estate of a nonresident who was not a citizen is taxed on US-situs property with the credit of USD 13,000, and a foreign death tax is relieved only by that country’s own rules.
One page per country
Each country page sets out the estate tax convention, the income tax convention, the death and gift taxes of the country and the library material on it.
Australia
1953
Austria
1982
Canada
Art. XXIX B
Denmark
1983
Finland
1952
France
FranceUSAlawtaxfinance.com
Germany
GermanyUSAlawtaxfinance.com
Greece
1950
Ireland
1949
Italy
1955
Japan
1954Netherlands
1969
South Africa
1947Switzerland
1951United Kingdom
1978Countries without a convention
Statutory regime
Sweden
Ended 2008
All treaty material
LibraryPhotos of the country are used where the firm has them; the other pages carry neutral photos until photos of the country are added.
The statutory regime applies, and the analysis still begins with the facts
Citizenship and domicile of the decedent or donor, the location of the assets and the residence of the heirs decide which rules apply where no convention does.