💼 Inheritance & Estate Taxes for Expats — The Global Picture

Moving overseas doesn’t just change your income tax obligations — it can also affect what happens when you inherit or pass on assets.
Each country handles inheritance tax (on the recipient) and estate tax (on the deceased’s estate) differently.

 

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🌍 What Expats Should Know

1️⃣ Different Countries, Different Rules

✅The U.S. taxes worldwide estates above exemption thresholds.

✅The U.K. applies inheritance tax (IHT) based on domicile, not residence.

✅Australia and Canada have no inheritance tax, but apply capital gains tax when assets are transferred.

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2️⃣ Tax Treaties Can Help — or Not Exist at All
Some countries have estate tax treaties that prevent double taxation, but most don’t.
→ Always check whether your home and host countries recognize inheritance tax relief.

 

3️⃣ Hidden Traps for Expats

✅Owning property abroad may trigger local estate or probate taxes.

✅Dual citizenship can complicate domicile and inheritance classification.

✅Joint accounts, trusts, or life insurance policies may fall under foreign rules.

 

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🧾 How to Protect Your Global Estate

✅ Draft a will that reflects your current country of residence.
✅ Review beneficiary designations (banks, pensions, life insurance).
✅ Consult a cross-border tax adviser for treaty-based estate planning.
✅ Keep records of asset cost bases and foreign valuations to avoid disputes.

 

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🦊 Felix Tip

Even if your country doesn’t levy inheritance tax, your heirs might still face one overseas. Plan your estate as if you’ll be taxed twice — then reduce exposure through treaties, trusts, or gifting strategies.

 

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• • An Australian expat → check the Australia Expat Tax Guide for superannuation rules.

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  • A Canadian expat → see the Canada Expat Tax Guide for RRSP and TFSA rules.

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  • For more insights, browse the full Expat Tax Tips & Insights.