No. of Recommendations: 1
In conclusion, and as I personally understand it (and again, this is NOT tax advice, this is NOT legal advice):
1. The estate of a UK domicile individual with under $60000 in US domicile assets (directly held!), has nothing to worry.
2. The estate of a UK domicile individual holding US domicile assets indirectly (e.g. via an Irish ETF), has nothing to worry about.
3. The estate of a UK domicile individual holding US domicile assets directly, worth over $60000, will have to file a US estate tax return, but can claim rights under the treaty reducing tax to zero.
4. The estate of a UK domicile individual holding US domicile assets directly, worth $12,060,000 or more, will have to pay US estate taxes as well as filing a US estate tax return.
Good info.
I will point out that the estate of a UK domicile individual will generally have to pay UK estate taxes at 40% for estates over the threshold (#325k individual, #650k couple). Got to pay for that great NHS somehow.