Naturalization does not raise the estate tax exemption of a green card holder who already lives in the United States. It changes the treatment of transfers from a spouse, the reach of the estate and gift tax treaties, the taxation of income after a move abroad, the status of minor children and the cost of leaving the United States tax system again.
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Summary A person who is neither a United States citizen nor domiciled in the United States is taxed at death on United States situs property alone, but against an exemption of only $60,000 and a top rate of 40 percent. The exemption for a citizen or a domiciliary in 2026 is $15,000,000. Situs is decided asset by asset, and the
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US persons have to declare foreign financial assets, foreign income and inheritances and trust distributions from abroad.
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International families often require careful and comprehensive tax and estate planning. What is the most tax-efficient way to hold assets such as brokerage accounts, businesses and real estate? What estate and inheritance taxes face the legatees of non-US citizens who have assets in the United States? After analyzing your situation we recommend tailored solutions.
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