Estate tax treaties can boost the NRA exemption via a prorated unified credit—if conditions are met. ⚖️

Offshore Tax with HTJ.tax · Apr 28, 2026 · 1m

The standard rule for non-resident aliens (NRAs) is harsh:• Only a $60,000 exemption • Based on a $13,000 unified creditBut in some cases, tax treaties can significantly improve this outcome.🌍 1️⃣ How Treaties Change the RulesUnder certain estate tax treaties, the Internal Revenue Code framework is modified.👉 Instead of the fixed $60,000 exemption:• NRAs may access a prorated unified credit📊 2️⃣ What Is a Prorated Unified Credit?The idea:• You calculate the ratio of:U.S.-situs assetsTo worldwide assets👉 Then apply that ratio to:• The full U.S. estate tax exemption available to citizens🧠…