Description
An adviser’s guide to the overlapping bases on which the United States and a European jurisdiction tax a death: the domicile-based conventions with Germany, France and the United Kingdom, and the parallel conventions with the Netherlands, Denmark and Austria, as the primary relief, with their tie-breakers, allocation rules, credit articles, saving-clause carve-outs and claim periods; the older situs conventions with Italy, Switzerland, Ireland and the other pre-1956 partners, with a treaty map of all fifteen treaty partners; the unilateral credit of section 2014 as the fallback, the election between the statutory and the treaty credit, and a worked example for a U.S. citizen domiciled in Germany; the reverse-direction credits under the German, French, British, Italian and Swiss statutes; the adjacent regimes of gift tax and the U.S. state death taxes; the residual double taxation that survives the lesser-of limitations, situs conflicts and timing mismatches; and the sequencing, proof and limitation periods on which the relief depends.
30 pages. Updated in September 2026.