You were paid in US shares. You are not American. Here is what that costs.
Most people who own US shares chose to buy them. You probably did not. You joined a US-listed company, part of your pay arrived as stock, and ten or fifteen years later a large part of what you own is a single holding in a single company. Two things are working against you, and neither is the share price.
Your family may owe the US government money
You joined a US-listed company, you were good at your job, and part of your pay arrived as stock. Restricted units that vested each quarter. A discounted purchase plan you signed up for in your first month and never revisited. Ten or fifteen years later, a large part of what you own is a single holding in a single company, denominated in a currency you do not spend, sitting in a broker account you log into twice a year.
Nobody sat you down and explained what that means for someone who is not American.
The United States taxes the estates of people who are not American, on assets it considers to be located inside the United States. Shares in a US-listed company are treated as US assets. Where you live, where your broker is, and where the share certificate sits make no difference.
The threshold at which this begins is USD 60,000.
That figure is not a typo. An American citizen who dies in 2026 can pass on USD 15,000,000 before federal estate tax applies. Somebody who is not American, holding the same shares in the same company, is sheltered on the first USD 60,000. Above that, a graduated scale applies which reaches 40%. At stake is whether your family inherits a portfolio or a bill.
Who this affects
Any employee of a US-listed company who is not a US citizen and has not acquired US domicile. Dutch, French, German, Spanish, British, Romanian and Australian professionals working in Singapore, Malaysia, Thailand, the Gulf, Hong Kong and continental Europe. The longer the tenure, the larger the position, and the larger the exposure.
Holding the shares somewhere else does not move them
The common assumption is that holding shares through a broker outside the United States moves you outside the US tax net. A Singapore brokerage account, an Isle of Man platform, a bank in Switzerland. It feels like distance should help.
It does not. For estate tax purposes the test is where the company is incorporated. Shares in a company incorporated in the United States are US assets no matter whose platform they sit on.
The point about nominees is worth dwelling on, because it is the one people argue with. The IRS states the position directly: stock of a corporation organised under US law is US-situated even where the non-resident held the certificates abroad, and even where they were registered in the name of a nominee.
What is not caught
Property generally treated as situated outside the United States includes certain deposits and debt obligations, money held with a foreign branch of a US commercial bank, and the proceeds of life insurance on the life of a non-resident who is not a US citizen.
Shares in companies incorporated outside the United States are also outside the net. So are funds domiciled outside it. That last exclusion is the whole of the structural answer, and we come back to it below.
Where a treaty applies, it can narrow the definition of what counts as US-situated in the first place, which is a different and sometimes better form of relief than an increased allowance.
Treated as US assets
Shares in US-incorporated companies, including every large listed technology employer. US-domiciled funds and exchange traded funds. Real property in the United States. Tangible property physically located there.
Generally not treated as US assets
Certain US bank deposits held by a non-resident. Shares in companies incorporated outside the United States. Funds domiciled outside the United States. Proceeds of life insurance on the life of a non-resident who is not a US citizen.
What the arithmetic actually looks like
Abstract thresholds do not land. Here is the position for three people, each holding vested stock in a US-listed employer, each not American, each living outside the United States. The figures are calculated on the current graduated federal schedule, with the credit available to a non-resident.
A Dutch engineer in Singapore, USD 420,000 in vested stock
Eleven years at the company, stock vesting quarterly throughout. He has never sold any of it, partly through inertia and partly because it kept going up. If he dies holding it, the US estate tax on that position is approximately USD 115,600. His family in the Netherlands receives the remainder, after a filing process in a country none of them has ever lived in, with a deadline that begins running from the date of death.
A French manager in Dubai, USD 1,200,000 in vested stock
Sixteen years, two promotions into a band where equity is most of the upside. She has a house in Lyon and no US connection beyond her employer incorporation. The US estate tax on that position is approximately USD 412,800. She pays no income tax in the UAE. That has no bearing here. The exposure attaches to the asset itself.
An Australian in Kuala Lumpur, USD 780,000 in vested stock
Twelve years with the company, most of it in Asia, intending to return to Australia eventually. The US estate tax on that position is approximately USD 247,000.
Each of these people is doing well. Each has been paid fairly by a good employer. None of them has done anything wrong. And in each case a substantial share of what they intended to leave behind is exposed to a tax they have never been told about, in a country they do not live in.
| Vested holding | Approximate US estate tax | Effective rate |
|---|---|---|
| USD 420,000 | USD 115,600 | 27.5% |
| USD 780,000 | USD 247,000 | 31.7% |
| USD 1,200,000 | USD 412,800 | 34.4% |
Does your country have a treaty that helps?
Sometimes. The United States has estate tax treaties in effect with fifteen countries: Australia, Austria, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, the Netherlands, South Africa, Switzerland and the United Kingdom. Canada operates through an article of the income tax treaty rather than a separate death tax treaty. Note that Norway and Sweden are sometimes still listed by secondary sources; neither appears on the current IRS list.
Where a treaty applies, it can materially change the outcome, sometimes by giving access to a much larger exemption calculated by reference to the American allowance.
Two points matter more than the list itself.
Look at where you live, not only at your passport. Singapore has no estate tax treaty with the United States. Neither does Malaysia, Thailand, the United Arab Emirates, Hong Kong, the Philippines, Vietnam or Indonesia. Nor do Spain, Portugal or Romania. A great many European professionals working in Asia and the Gulf hold a nationality that appears on the treaty list while living somewhere that does not appear on it at all.
These treaties also work by reference to domicile rather than residence, and the two are not the same thing. Domicile is a question of permanent home and intention. Somebody who left the Netherlands twenty years ago, has no property there, and has raised a family in Singapore may find their position is not the simple one their passport suggests.
Whether a treaty helps you is a question with a real answer, but it is specific to your circumstances and it is worth establishing before it matters rather than after.
No estate tax treaty with the United States
Singapore. Malaysia. Thailand. United Arab Emirates. Hong Kong. Philippines. Vietnam. Indonesia. Spain. Portugal. Romania. If you are domiciled in one of these, there is no treaty relief to fall back on.
How the bill actually gets paid, and who pays it
Where a non-resident who was not a US citizen dies holding US-situated assets with a fair market value above USD 60,000, the executor is required to file a US estate tax return. That is a filing obligation triggered by the value of the assets, not by whether any tax proves payable. A family with USD 400,000 of employer stock and no other American connection acquires a US tax filing.
Two consequences follow, and both are practical rather than theoretical.
The assets are difficult to move until it is resolved. Transfer agents and brokers holding US securities for a deceased non-resident will generally want evidence that the US position has been dealt with before releasing anything. In the meantime the holding sits where it is, exposed to the market, while the family waits.
The liability can also follow the money. The IRS states that it may collect unpaid estate tax from any person who received a distribution of the deceased person property. If the estate distributes and the tax goes unpaid, the people who received the assets can be pursued for it. An inheritance can arrive and then be clawed at.
This is why finding out early matters more than the arithmetic suggests. The tax is a number. The process is months of it, handled by people who are grieving, in a system none of them has used before.
Everything you own moves together
Set the estate tax aside for a moment, because there is a separate issue sitting alongside it.
Being paid in employer stock produces a concentration that nobody would choose deliberately. Your salary comes from the company, so does your bonus, and by now so does most of what you have saved. When the business has a difficult year, all three move together.
This is not theoretical. In the first quarter of 2026, Microsoft shares fell from USD 483.62 to USD 370.17. A holding of 5,000 shares was worth about USD 2,418,100 on the first of January and about USD 1,850,850 at the end of March. That is a fall of roughly USD 567,000 in three months, in a company nobody regards as speculative.
The shares may well be a fine investment. The difficulty is that a position of that size, in one company, in one currency, alongside a salary from the same employer, is a structural decision nobody actually made. It happened by default, one vesting date at a time.
Most people in this position know it. What they lack is a reason to act this quarter rather than next.
Not all of your equity is necessarily the same
Most people in this position hold some combination of restricted units that have vested, shares bought through a discounted purchase plan, and sometimes options that have not been exercised. These are not automatically identical for tax purposes, either where you live or in the United States, and unvested awards raise different questions again from vested shares you already own outright.
If you also hold a US retirement account from an American employer, that is a separate question with its own treatment and it should not be assumed to follow the same rules as the shares.
Before deciding anything, get a single list of what you actually hold, split by type, with values against each line. Most people have never written it down in one place, and the exercise itself usually changes the conversation.
One quarter, one company
Microsoft shares fell from USD 483.62 to USD 370.17 between January and March 2026. On a 5,000 share holding that is a fall of roughly USD 567,000 in three months. Concentration is not a theoretical risk for someone paid in employer stock. It is the default position.
What actually solves the estate tax problem
The structural answer is straightforward, and it is the same answer we give clients across every nationality we work with.
Funds domiciled in Ireland, structured as UCITS, are not US assets for estate tax purposes. They track the same indices. They hold the same underlying companies. An Irish-domiciled fund tracking the S and P 500 gives you the same market exposure as a US-domiciled fund tracking the S and P 500.
The performance difference is negligible. The structural difference is material.
For a person who is not American this is not a close call, and it has been our default position for globally mobile clients for years. The Irish-domiciled version does the same investment job without leaving your family a US filing obligation and a bill calculated at up to 40%.
Moving from concentrated employer stock into a diversified structure does two things at once. It removes the US estate exposure, and it addresses the concentration. Those are usually treated as separate conversations. For someone paid in employer stock they are one conversation.
What this does not solve
Selling has consequences of its own. Disposing of vested stock may create a taxable gain where you live, or where you are domiciled, or both. In some situations it creates nothing at all. This depends entirely on your own position and it is the first thing to establish, before any decision about what to buy next.
Timing is not neutral either. The answer to whether you should sell is often different depending on where you are tax resident at the moment you sell, and different again if you are planning to move. For anyone with a return to their home country in mind, the sequence matters as much as the decision.
And your employer rules still apply. Blackout periods, insider windows and internal approvals do not disappear because a plan is sensible. Any restructuring has to be built around them. Each of these is a reason to plan the move rather than react to it.
Get the employer stock and US estate tax guide
A structured guide covering US-situated assets, the USD 60,000 threshold, the estate tax treaty position by country, and the Irish UCITS alternative. Written for non-American employees of US-listed companies.
Why the answer changes when you move
Your tax position is a function of where you are resident, and for many people that changes at least once more before they retire. The rules that apply to a Dutch national in Singapore are not the rules that apply to the same person after they move back to Amsterdam. The same is true for an Australian returning to Sydney, a German going home to Munich, or a Briton retiring to Portugal.
What that means in practice is that there are moments when restructuring is straightforward and moments when it is expensive, and the two are often separated by a single flight.
The US estate tax exposure described above travels with you regardless. It is created by what you own, and it follows the holding wherever you live. That part does not improve by waiting.
The rest of it, the capital gains position and the timing, is specific to the jurisdictions involved and needs to be worked out properly rather than assumed.
The order to do things in
First, establish what you hold and what it is worth, by type, in one list. This costs an hour, and nothing else can be decided without it.
Second, establish your own tax residence and domicile position, and whether a treaty is available to you. This determines the size of the problem and whether any relief exists.
Third, establish what selling would cost you where you live, before deciding whether to sell. For some people this is nothing. For others it is the largest number in the exercise. It is not safe to assume either.
Fourth, check your employer dealing rules and when the next open window falls.
Only then decide what to hold instead. The investment decision is the easiest part of this, and it is where most people start.
Four questions to answer this month
What is the total value of your holdings in US-incorporated companies, including any old brokerage account you have stopped thinking about? Does your country of domicile appear on the treaty list? What proportion of your net worth sits in one company shares? Do the people who would deal with your estate know these holdings exist and how to reach them?
Common questions on US estate tax and employer stock
I hold my shares with a broker outside the United States. Does that help?
No. What matters is where the company is incorporated, not where the account is held.
Does this apply if I have never set foot in the United States?
Yes. The exposure comes from the asset, not from any personal connection to the country.
My spouse would inherit everything. Is there not an unlimited exemption between spouses?
The unlimited marital deduction is available where the surviving spouse is a US citizen. Where the surviving spouse is not, it is not available in the same way, and other arrangements are needed. For most readers of this page, neither spouse is American, which puts them squarely in the harder case.
What is the threshold again?
USD 60,000 of US-situated assets for someone who is not American or US-domiciled. USD 15,000,000 for a US citizen dying in 2026.
Is it really 40%?
The schedule is graduated and reaches 40%. The worked examples above show the effective outcome at three realistic holding sizes.
I plan to sell everything before I die anyway.
Most people do. The difficulty is that estate tax applies at a date nobody schedules. The exposure exists for as long as the holding does.
Should I just sell it all now?
Not necessarily, and not without establishing your own capital gains position and your employer dealing rules first. The right sequence depends on where you are tax resident and whether you are planning to move.
Are Irish-domiciled funds worse investments?
No. They track the same indices and hold the same companies. The difference is structural rather than in performance.
What this means if you are living in Asia or the Gulf
If you are a European or Australian professional living in Southeast Asia or the Gulf, earning in one currency, spending in another, with retirement assets somewhere else again, this holding is probably the largest single thing you own and the least deliberately chosen.
It arrived one vesting date at a time. It carries a tax exposure in a country you do not live in, at a threshold most people would assume was a mistake, with no relief available in most of the places our clients actually live.
None of that calls for panic, and none of it is a question about market timing. The share price will do what it does. The structure underneath it is the part you control, and the part that decides what your family actually receives.
Getting the structure right matters more than getting the selection right.
Review the US estate tax exposure in your employer stock
If you hold vested stock in a US-listed company and you are not American, reviewing the position is a straightforward exercise. A session covers what you hold, whether a treaty is available to you, what a sale would cost where you live, and the structural alternatives. You will get a straight answer about your exposure whether or not you go any further.
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