Residents of Switzerland who are not U.S. citizens and do not live in the U.S. will be taxed by the U.S. at the time of death on assets located in the U.S. to include:
- Real property, livestock and equipment located thereon
- Certain tangible property
- Debts or obligations from the U.S. government, U.S. municipalities or corporations
- Negotiable promissory notes from a U.S. person or legal entity
- Shares of stock in a U.S. corporation
- Goodwill in a business carried on in the U.S.
- Patents, trademarks and designs registered in the U.S.
- Copyrights licensed in the U.S.
- Rights or causes of action arising in the U.S.80
The applicable U.S. estate tax (but not the gift tax) can be reduced by a pro rata share of the $1,455,800 credit against tax. The share of this credit is based upon the percentage that the U.S. estate bears to the entire worldwide estate determined by the following calculation:
$1,455,800 x Value of estate situated in the U.S.
Value of entire gross worldwide estate.81
The U.S. will tax all gifts of tangible property or real property located in the U.S. at the time of the gift in the same manner as gifts made by any other non-citizen not domiciled in the U.S.
Citizens of Switzerland living permanently in the U.S. will be taxed by the U.S. on the transfer by gift or at death of any assets regardless of where they are located in the world. The tax imposed by the U.S. and any applicable exemptions and credits are those available for any non-citizen domiciled in the U.S. (See answers 4, 5 and 6.)