The US estate tax applies to US citizens and US donminciled no matter where they are residing and no matter where their assets are located.

 

The US estate tax generally only applies to non-US persons who have US situs assets at the time of death or gifting.

 

When a non-US person’s estate is subject to US estate tax, the tax advisor must understand the US domestic estate tax framework and the applicable treaty (in the case of Canada or China, the Canada-US or China-US income tax treaty; the United States also has estate and gift tax treaties with a number of countries).