Cross-border inheritance creates double-taxation nightmares
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When someone with assets in multiple countries dies, each country applies its own inheritance or estate tax rules independently, and bilateral tax treaties covering inheritance exist between very few country pairs. A US citizen who owns property in France, for example, faces US federal estate tax (40% above $12.92M exemption), plus French succession tax (up to 60% for non-family), with only a partial foreign tax credit available. So what? The combined effective tax rate can exceed 70%, sometimes making it financially irrational to have inherited the asset at all. So what? Immigrant families who maintain property in their home country, expats with overseas retirement accounts, and globally mobile professionals face estate tax bills that would require selling the very assets being inherited to pay the tax on inheriting them. So what? Families are forced to make fire-sale liquidations or simply abandon overseas assets because the cost of compliance exceeds the asset value. This persists because inheritance tax treaties are rare (the US has treaties with fewer than 20 countries), each country's rules change independently, and very few attorneys are qualified to advise on multi-jurisdictional estate planning, with those who are charging $500-1000/hour.
Evidence
The US has estate tax treaties with only 16 countries. France's succession tax for non-relatives is 60%. The UK charges 40% inheritance tax on worldwide assets of UK-domiciled individuals. A 2023 EY Global Tax Alert documented cases where combined cross-border estate tax exceeded 80% of asset value. The Migration Policy Institute reports 45 million immigrants live in the US, many with property in their country of origin. A Deloitte survey found fewer than 3% of estate attorneys are qualified to handle multi-jurisdictional estates.