QUOTE(danmooncake @ Jan 7 2015, 11:14 PM)
I'm not sure it will be that high unless you got millions to pass on.. are u sure about this?
But depending on your filing status... (resident vs non-resident) and if you can still get tax-exempt on non-resident
for cap gains, perhaps best to put your account in joint account status and one of the survivor can execute the securities sale
without going thru inheritance/real estate transfer.
Yup - good idea. Unfortunately my spouse isn't too.. er.. versed with stocks, options, etc. + my children are currently all below 18
Sharing - for those who believes one doesn't know WHEN one will "go" & investing or trading for their family in non-joint accounts, thus be prepared:
Pls note - 45% was what i saw in a broker's website (forgot where - just saw in Dec 2014) but updates due to "Obama tax reforms" (see last link below), it's up to 55% in 2013. Gawd knows for years 2014 and further.
http://www.irs.gov/uac/SOI-Tax-Stats-Nonre...-Study-MetadataWhat is the Nonresident Alien Estate Tax?The nonresident alien estate tax is one part of the Federal transfer tax system, which is incurred on transfers of property at death. The nonresident alien estate tax, reported on forms 706-NA, United States Estate (and Generation-Skipping Transfer) Tax Return,
must be filed by nonresident aliens with $60,000 or more in U.S. gross assets.
The U.S. gross estate of nonresident aliens may be composed of tangible personal or real property, as well as intangible assets such as stock or debt obligations. Tangible personal property and real property owned by the nonresident alien must be physically located in the United States for it to be included in the U.S. gross estate.
Intangible property is included in the U.S. gross estate based on different criteria. The stock of U.S. corporations is considered part of the U.S. gross estate regardless of where stock certificates are physically located. Debt obligations issued by a U.S. citizen, resident, business, trust, or Governmental organization are likewise treated as part of the U.S. gross estate of nonresident aliens. For estate tax purposes, the values of the nonresident alien decedent’s U.S. assets are based on the fair market value at either the decedent's date of death, or at aln alternate valuation date. The alternate valuation date, which must be within six months following the date of death, may only be used if the value of the estate, as well as the estate tax, is reduced between the date of death and the alternate date.There are two broad types of nonresident alien estate tax forms filed: treaty status returns and nontreaty status returns. Treaty status returns are filed for nonresident aliens who held assets in the United States worth $60,000 or more at the time of death, and who were domiciled in countries with which the U.S. had an applicable estate tax treaty. The United States holds estate tax treaties with 17 countries: Australia, Austria, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, Netherlands, Norway, Republic of South Africa, Sweden, Switzerland, and the United Kingdom. The treaties differ among countries, but the basic provisions include mutual administrative assistance between the U.S. and each country and the avoidance of double taxation. Nontreaty status returns were filed for nonresident aliens who held assets in the United States worth $60,000 or more at the time of death but were domiciled in countries without an applicable estate tax treaty.
...
http://www.daypitney.com/news/docs/dp_3952.pdfNote - printed 2012
B. Estate Tax: Estates of NRA individuals are subject to U.S. estate tax only on U.S. situs assets.
The tax is assessed
at the same rates as for U.S. citizens, up to 35% for 2011 and 2012, but with only a $60,000 exemption
(as opposed to the current exemption of $5,000,000 for a U.S. person). (I.R.C. § 2106 (b)) Worldwide debts
and administration expenses may be deducted, but only in the proportion that the U.S. assets bears to the
decedent’s worldwide assets.
The unlimited marital deduction is available; however, if the surviving spouse is
not a U.S. citizen, only property left to a Qualified Domestic Trust (QDT) will qualify (see Section VIII (B)
below). The charitable deduction is available only for bequests to U.S. charities.
U.S. Situs Assets for Estate Tax Purposes: The following is a partial list:
- U.S. situs real property, including houses and condominiums. (Treasury Reg. §§ 20.2104-1 (a)(2);
20.21051 (a)(2))
- U.S. situs tangible personal property, such as jewelry, antiques, artworks and cars, unless the items are in
transit or on loan for an exhibition. (Treasury Reg. §§ 20.2104-1 (a)(2); 20.21051 (a)(2))
- Shares of stock of U.S. corporations, including shares of a U.S. co-operative corporation representing a
co-op apartment. (I.R.C. § 2104(a)) Shares of non-U.S. corporations are not U.S. situs property. The
location of the certificate is immaterial. Mutual funds (including money market funds) organized in corporate
form are U.S. situs property if incorporated in the United States. (I.R.C. § 2104(a)) If the fund
is structured as a partnership or grantor trust, the situs of the fund depends on the situs of the underlying
assets of the fund.
- Cash deposits with U.S. brokers, money market accounts with U.S. mutual funds and cash in U.S. safe
deposit boxes are U.S. situs property. (I.R.C. § 2104 ©)
- Debts of U.S. obligors. Once again, however, publicly traded bonds issued after July 18, 1984 qualify as
“portfolio debt” and therefore are not subject to U.S. estate taxation. (I.R.C. § 2105 (b)(3)) Previously,
only bonds with a maturity of more than 6 months qualified for the estate tax portfolio debt exemption,
so that short-term Treasury bills, for example, were U.S. situs assets. However, this distinction was eliminated
by the Taxpayer Relief Act of 1997, and bonds now qualify for the portfolio debt exemption regardless
of maturity.
- Interests in limited or general partnerships that either do business in the U.S. or own assets in the U.S.
will probably be considered U.S. situs assets.
- Life insurance proceeds paid by a U.S. insurer on the life of a non-U.S. person is not U.S. situs property.
However, the cash surrender value of life insurance owned by a non-U.S. person on the life of another person
is U.S. situs property if issued by a U.S. insurer. (Treasury Reg. § 20.2105-1 (g))
Bank accounts maintained with U.S. banks are not U.S. situs property: this includes checking and savings
accounts, time deposits and certificates of deposit. (I.R.C. § 2104 ©)
Again, treaties with various countries can alter these rules, particularly as to whether U.S. stocks owned by a
citizen and resident of another country will be taxed by the U.S.
...
http://www.blankrome.com/index.cfm?contentID=37&itemID=3254Estate Planning for Nonresident Aliens. The estate of a nonresident alien (“NRA”) (a noncitizen who is not a U.S. resident) has only a $60,000 (not $5,340,000) estate tax exemption available. U.S. donees of gifts from NRAs or foreign estates in excess of $100,000 [or $15,358 in 2014 (inflation adjusted) from a foreign corporation or partnership] must report these gifts to the IRS on Form 3520. Several interesting planning opportunities may exist for an NRA.
An NRA may avoid transfer taxes completely by structuring his or her holdings so that no U.S. “situs” assets are owned directly (for example, U.S. “situs” assets may be held by a wholly-owned foreign corporation, although U.S. real estate presents special income tax issues). If your spouse is not a U.S. citizen, you may wish to defer estate taxes by use of a “qualified domestic trust” (discussed in paragraph 6). Lifetime gifts by an NRA of U.S. “situs” intangible personal property (such as stock or partnership interests) are not subject to U.S. gift taxes, even though these items might be subject to U.S. estate taxes if owned by the NRA at death. An NRA also may wish to establish a trust to hold property for U.S. resident children or other family members to provide them with tax-free income and arrange for the trust property to pass to other family members free of transfer taxes.
...
http://www.taxanalysts.com/www/features.ns...37?OpenDocument...The U.S. federal estate tax rates are among the highest in the world.
1
The current top estate tax rate following President Obama's tax reform is 35 percent, and it is scheduled to increase to 55 percent in 2013.
2 The amount that a nonresident alien can exempt from estate tax is fairly low, $60,000 of U.S.-situated assets. Consequently, estate tax exposure may be a significant concern for a foreign investor accustomed to paying minimal or no estate tax in his home country and who is interested in investing in U.S.-situated property.3. The surest way for an NRA to avoid U.S. estate tax exposure is to hold his U.S.-situated assets via a foreign corporation. However, there are significant disadvantages to this approach:
if the NRA holds, via a foreign corporation, assets upon the disposition of which he is subject to tax in the United States (such as real property), the NRA is unable to benefit from the reduced long-term capital gains rate of 15 percent available to individuals;
he is exposed to branch profits tax;
in some instances, he will have higher ordinary income tax rates; and
he will possibly incur additional foreign taxes due to using a foreign corporation to hold his U.S.-situated assets...
This post has been edited by wongmunkeong: Jan 8 2015, 08:18 AM 
Nov 10 2014, 10:16 AM
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) with minimum $9.95 or higher per trade 
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