Newroad wrote:Does anyone have sufficient international tax expertise to verify how that reads to me - that upon death, the estate of a UK-resident holder of IRE domiciled ETF's, such as the two named, would be subject to US Estate Tax if the US assets exceed $60K?
What the author is trying to say here, and unfortunately hasn't said entirely clearly, is that non-US investors who held the underlying US assets directly (or, though US domiciled ETFs) could face US estate tax on holdings above $60,000, but holding these same US assets through an Ireland domiciled ETF insulates non-US investors from rapacious US estate taxes, while at the same time these Ireland domiciled ETFs are not at any risk from Irish inheritance tax when held by non-Irish investors.
The article's author lives in Singapore, and he's writing this for Singaporean investors. Singapore has no US estate tax treaties, so the $60k limit is something Singaporean investors need to worry about. (Also, because of the $60k exemption the US estate tax rates actually work out to 26%-40%, not 18%-40% as written.) The UK does however have a US estate tax treaty, and this protects UK investors up to (and in some cases, even above) the standard $11m or so US estate tax exclusion allowed to US investors.
In other words, as a (presumed!) UK investor you can realistically ignore US estate tax issues. If you invest through Ireland domiciled ETFs then you are covered that way. And if you hold any 'US situs' assets directly, such as shares or -- now difficult, thanks to PRIIPs -- US domiciled ETFs, you have cover from the US/UK estate tax treaty.