Die holding US Stocks and pay 40% tax? — What Singapore investors need to know about US inheritance / estate tax

Good article from Financialhorse.com 👍
https://financialhorse.com/die-holding-us-stocks-and-pay-40-tax-what-singapore-investors-need-to-know-about-us-inheritance-estate-tax/

The United States maintains estate and gift tax treaties with a specific group of 15 countries. These agreements are designed to prevent double taxation by providing rules for determining tax residency and allocating taxing rights between the two countries. Here are the 15 countries that have an estate or gift tax treaty with the U.S.:

Country	Treaty Type
Australia	Estate & Gift
Austria	Estate & Gift
Canada	Estate*
Denmark	Estate & Gift
Finland	Estate
France	Estate & Gift
Germany	Estate & Gift
Greece	Estate
Ireland	Estate
Italy	Estate
Japan	Estate & Gift
Netherlands	Estate
South Africa	Estate
Switzerland	Estate
United Kingdom	Estate & Gift

*Note: The estate tax provisions for Canada are contained within Article XXIX B of the U.S.–Canada Income Tax Treaty.

Important Considerations

• Purpose: These treaties are primarily used to address "tie-breaking" issues, where both countries may assert that an individual is domiciled within their jurisdiction for tax purposes. By allocating the right to tax, they help avoid instances where an estate is subjected to tax in both nations.

• Treaty Variations: Not all treaties are the same. For example, some include tie-breaking rules, while others (like the treaty with Switzerland) do not. Some also include provisions regarding marital deductions for non-U.S. citizen spouses or allow for a prorated increase of the U.S. estate tax unified credit.

• Official Source: For the most accurate and up-to-date legal text, you should refer to the Internal Revenue Service (IRS) Estate & Gift Tax Treaties page.

Because estate tax law is highly complex and involves specific international legal agreements, it is strongly recommended that you consult with a qualified tax attorney or accountant who specializes in cross-border or international estate planning if you are managing assets in multiple jurisdictions.