Deleted user
posted a year ago
Dual citizenship in the US and Netherlands but domiciled more than years in the Netherlands
I am wondering under what conditions I could choose the US tax regime in my will should I pass away, if I've been physically domiciled in Europe. (2010-2023 will be France, then moving back to the Netherlands in 2024--I'm 69, and don't expect to die any time soon). I wonder whether it might not be best to have part of my inheritance from my US domiciled mother skip a generation and go directly to my children. My daughter has three passports and resides in the UK (UK, Dutch and US). My son lives in the US. WOuld be grateful for an answer.
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  • United Kingdom
  • Netherlands
  • United States
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  • Tax
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toausif12345
Deleted user
Lawyer
posted a year ago
Yes
anneregier2022
Deleted user
Lawyer
posted a year ago
US have no inheritance tax (although look at the individual state regulations where your mother resides). Both the UK and Netherlands have inheritance tax. If you pass the property to your daughter. Both the UK and Netherlands tax you on your worldwide income. So, it may make sense for you to transfer the property to your mother for purely financial reasons.
anneregier2022
Deleted user
Lawyer
posted a year ago
US have no inheritance tax.
anneregier2022
Deleted user
Lawyer
posted a year ago
As far as I know, the US has no inheritance tax as such, although you need to check individual state regulations. Which country your daughter is domiciled in? Meaning she lives more than 6 months a year in? There is where she should usually pay tax. UK, Netherlands and UK all have double taxation treaties, meaning your daughter should not be 2x or 3x taxed. Both the UK and Netherlands have inheritance tax. So it may make sense for you to transfer the inheritance to your mother for purely financial reasons.