Prorated Credit Calculation for Estate Tax

Offshore Tax with HTJ.tax · Apr 29, 2026 · 1m

For non-resident aliens (NRAs), estate tax treaties can unlock a powerful benefit:👉 Access to a prorated share of the full U.S. unified creditInstead of being limited to the standard $60,000 exemption, eligible taxpayers can calculate a proportional exemption based on their global wealth.⚖️ 1️⃣ The Core FormulaUnder treaty provisions modifying the Internal Revenue Code:👉 The unified credit is calculated as:(U.S.-situs assets ÷ Worldwide assets) × Full U.S. unified credit📊 2️⃣ How It Works (Conceptually)Step 1: Identify U.S.-Situs Assets• U.S. real estate • U.S. securities • Other assets…